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Last updated: 03/03/10

Policy Statement

TRUSTe Click to verifyToLuna USA, Inc., (“ToLuna USA)” adheres to the principles set forth in the Safe Harbor framework as established by the U.S. Department of Commerce regarding the collection, use, and retention of personally identifiable information provided to ToLuna USA from the European Union.

This overall Privacy Statement verifies that ToLuna USA is a member of the TRUSTe program and is in compliance with TRUSTe privacy principles. This statement discloses the privacy practices for the entire us.toluna.com website.

TRUSTe is an independent, nonprofit initiative whose mission is to build users' trust and confidence in the Internet by promoting the principles of disclosure and informed consent. Because ToLuna USA wants to demonstrate its commitment to your privacy, we have agreed to disclose our information practices and have our privacy practices reviewed and audited for compliance by TRUSTe. When you visit a website displaying the TRUSTe mark, you can expect to be notified of the following:

  • What information this site gathers/tracks about you.
  • What this site does with the information it gathers/tracks.
  • With whom this site shares the information it gathers/tracks.
  • This site's opt-out policy.
  • This site's policy on correcting and updating personally identifiable information.
  • This site's policy on deleting or deactivating your name from its database.
  • Notification of changes.
  • This site's policy regarding security.
  • This site's policy regarding business transfers.
  • This site's policy regarding links to third-party sites.
  • This site's policy regarding legal disclaimers.
  • This site's policy regarding children's privacy.
If you have questions or concerns regarding this statement, you should first contact Privacy Officer at privacyna@toluna.com . If you do not receive acknowledgement of your inquiry or your inquiry has not been satisfactorily addressed, you should contact TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php TRUSTe will then serve as a liaison with us to resolve your concerns. ToLuna USA complies with the EU Safe Harbor framework as set forth by the Department of Commerce regarding the collection, use, and retention of data from the European Union
Commitment
ToLuna USA is an online data collection company focused on providing high quality data to the full-service marketing research industry, advertizing agencies and consultancies. We build and maintain large online consumer Panels. You can be assured your privacy and the confidentiality of your information is our number one priority. All of the data that ToLuna USA collects in our research studies report as aggregate information, that is, information about groups - not individuals. Individual information is never reviewed or published without your consent, as it is irrelevant to the research conducted by our clients. All individual information provided is held confidential in accordance with the terms of this Privacy Policy.
The Information We Gather
ToLuna USA gathers personal information when individuals register to become member of our panels, after registration we ask panel members to provide us with more personal information so that we may invite them to appropriate surveys. To become a panel member, we ask that you fill out a registration survey that gathers some personal and general consumer information. We ask for your email address so that we can send you email invitations to participate in our upcoming surveys. The other information we gather, such as your name, address, gender, birthday, and employment status, is for matching you with the appropriate marketing research projects. Your birthday is used to automatically update your age for us to target age-related marketing groups. We ask you for this information as a means to see if you might qualify for particular projects. All email contact from ToLuna USA will be sent to your primary email address that you gave to us upon registration. If you become a panel member, your information (name, address, city, state, and Zip) is also used for the purposes of incentive fulfillment. When incentive points are deposited in your account and you wish to redeem them, this information is required so that we may send your reward to the appropriate recipient address. From time to time, a third party may be used for issuing checks or processing the delivery of rewards; your personally identifiable information will not be used for any other reason, but to mail you your reward.

If you take a survey or provide us with personal information without being a member of our panel, the only personally identifiable information we will preserve is your email address, gender, age, ethnicity and zip code, machine ID and IP address. We do this so we may contact you if you have won a prize or are entitled to an incentive, to match you to appropriate surveys and improve the user experience. Unless you elect to become a member of the ToLuna USA panel, we will not contact you for any reason other than to notify you that you have won a prize or are eligible for an incentive. If you are entitled to a prize or an incentive, we will collect and maintain such personally identifiable information, as we are required to maintain or report by virtue of any law or regulation.

If you use the Community Forum Area on our website to post blogs, bulletins or chat with fellow community members, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these forums.
Use of This Information
ToLuna USA does not sell or transfer the personally identifiable information collected about the members of its panels or the individuals that take surveys for us. Information which is personally identifiable will only be transferred with your prior permission on a case by case basis. If you are a member of the ToLuna USA panel, your information is stored in our proprietary database so we may call upon it to determine which people match up with specific research studies. If we think your profile makes you a potential candidate for a study, we will email you an invitation to make you aware of this opportunity. From time to time ToLuna USA may use third-party software for email list management and email distribution, or may use third party list management providers to match the members of our Panel to members of other lists or panels, or to validate accuracy of personal information you provide. We may use third parties to provide us with data they have collected about you, and append this data to your demographic profile. In such cases only a minimum amount of information is transferred to these third parties so as to enable them to perform specific functions on our behalf.
The Use of Cookies on Our Site and Digital Finger printin Cookies:
One or more "cookies" will be placed on the hard disk of the computer(s) used by site visitors, panelists and survey takers in order to allow ToLuna USA to recognize the participant when they connect to the ToLuna website, in order to facilitate the management of ToLuna USA, for statistical purposes (pages consulted, date and time of consultations etc.), and to enable us to provide the participant with surveys specifically tailored to his / her interests. This cookie identifies tags contained in certain on-line advertisements relating to our clients. It will update us when you interact with these ads so we can send you relevant surveys for you to complete. This will not affect the performance of your computer but simply provide you with additional opportunities to receive more surveys relevant to your interests.

Only information collected by cookies as specified in this section of our privacy policy is automatically collected from users of the Site. In the event that we do collect any personal data about visitors to the Site it is available only to ToLuna USA.

By the use of the Site all Site users authorize cookies to be put in place and their use by ToLuna USA and ToLuna USA’s clients and business partners. The cookies will expire after one year

Site users may disable the installation of "cookies " or to delete cookies installed by ToLuna USA or its clients. To do so you should modify your browser settings click on the help section of your Internet browser and follow the instructions.
Digital Finger printing
In general, digital fingerprinting technologies assign a unique identifier or “Machine-ID” to a user’s computer to identify and track the computer. ToLuna USA will not use digital fingerprinting technology (the “Technology”) to collect Personal Information, or track the online activities, of the user of a computer; and will not disrupt or interfere with the use or control of a computer or alter, modify or change the settings or functionality of a computer. ToLuna USA will use the Technology to assist ToLuna USA’s clients in ensuring the integrity of survey results. The Technology will analyze publicly available information and data obtained from the computer’s web browser and from other publicly available data points, including without limitation the technical settings of the computer, the characteristics of the computer, and the computer’s IP Address, to create a unique identifier assigned to the computer. The unique identifier will be an alpha-numeric id. After creating the unique identifier, ToLuna USA does not retain the information analyzed by the Technology to create the unique identifier. In furtherance of ToLuna USA’s efforts to assist its clients in protecting and ensuring the integrity of survey results, ToLuna USA (a) may link or associate your unique identifier to you and any of your Personal Information; (b) may share your unique identifier with ToLuna USA’s clients and with other sample or panel providers; and (c) may receive or obtain a unique identifier linked to you from a third party, including without limitation a sample or panel provider or a client of ToLuna USA. Any unique identifier(s) received or obtained by ToLuna USA and linked to a specific individual will be protected in accordance with this Privacy Policy.

ToLuna USA shall use commercially reasonable efforts to ensure that the Technology is safe, secure and do not cause undue privacy or data security risks.

ToLuna USA shall use and distribute the Technology in a professional and ethical manner and in accordance with (a) ToLuna USA’s privacy policy, (b) any statements and/or disclosures made by ToLuna USA to respondents, and (c) applicable Laws and Codes.

In the event that ToLuna USA discovers or learns of any unethical conduct in connection with the use of the Technology, or that the Technology is being used in a manner that is inconsistent with the statements and/or disclosures made by ToLuna USA to respondents or in violation of applicable Laws and Codes, ToLuna USA will take immediate action to prohibit such unethical conduct and to ensure the proper administration of the Technology.
Member Services Area/Update, Correct, Delete Information
We provide you with a Members Area on our site; here you may correct or update your membership information or delete your membership. If you are a Panel member and delete your membership, all your profile information will be permanently removed from our database, but may be stored in our disaster recovery databases, and in such circumstances will not be used for commercial purposes. Please note that in some cases it may take two to three business days for your information to be completely removed from our records.
Opt-Out Policy
By becoming a ToLuna USA panel member, you agree to receive emails inviting you to participate in surveys that we feel may match your experiences and background. You also agree to the automatic establishment of your personal prize account. From time to time, we will also email newsletters to you to make you aware of new features or contests running on our site. You may update your registration information at any time. Please see Correct/Update Policy below.
Correct/Update Policy
If you need to correct any of your profile information or if you would like to update any of your information, you may automatically do so by clicking on any of Your Profiles found in the Members Area. By following the appropriate directions, your information should be automatically updated in our database.
Delete/Deactivate Policy
If you choose to end your membership with ToLuna USA, you may automatically discontinue your membership by clicking on Unsubscribe under My Account Maintenance found in the Members area. By following the appropriate directions, your record will be marked as "do not contact", and you will no longer receive communications from ToLuna USA. In addition, you will forfeit any incentive balance that has not been requested as of the time you opt out. Please allow two to three business days for processing of this change. In the meantime, you may receive emails from us and we apologize for any inconvenience this may cause. As an alternative, you may send an email directly to SupportNA@toluna.com , requesting to be removed. Email links are provided on the site so that you may contact us directly with any questions or concerns you may have. Each email we receive is read and responded to individually; please allow two to three business days for us to get back to you
Winners Policy and Privacy Guarantee
Panel members and others who take our surveys are randomly selected to win prizes for participation in surveys, polls, and other promotions. All winners are notified by email of their winnings. Once we deposit winnings in accounts, panelists have the option to request that a check be mailed to them at any time. For more information, please visit our Terms and Conditions page. Cash and other prizes awarded to non-panel members will be awarded directly. Occasionally we ask a prizewinner to grant us permission to post his/her name on the Winners page on the ToLuna USA website. We will never post a name on our Winners page without an individual's prior permission.
Notification of Changes
If we decide to change our privacy policy, we will post those changes to this privacy statement, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page
Security
ToLuna USA takes strict measures to ensure every aspect of your information is kept secure. Access to all personal information is restricted and limited to few key personnel. Our website security is reviewed periodiclayy and can only be accessed via a strict password policy. ToLuna USA will never ask you for private information such as your credit card or social security numbers as a part of our research. We may be required by law to ask for your social security number to comply with reporting laws and regulations if you are the recipient of survey incentives. Your profile information is highly confidential and will be used only by ToLuna USA to email you concerning our studies, newsletters, winner notifications, and incentive redemptions, or as otherwise provided for in this privacy policy.
Business Transfers
As we continue to develop our business, we might sell or buy additional assets. In such transactions, ToLuna USA’s right to contact its panel members and the information you have voluntarily provided in your user profile would generally be one of the transferred business assets. Any sale or transfer of ToLuna USA or substantially all of its business assets, which included our panel, would be to an entity that agreed to comply with all of the material terms of our privacy policy.
Links
From time to time we may offer visitors the ability to voluntarily link to other sites. ToLuna USA does not review, and is not responsible for, the content or effect of the privacy policies of these sites.
Legal Disclaimer
We may disclose personal information when required by law or in the good-faith belief that such action is necessary to conform to the edicts of the law or to comply with a legal process served on our website
 
Children's Privacy
 
ToLuna USA will not knowingly collect any information from any individual under the age of 13 without permission from his/her parents or legal guardian. ToLuna USA is in adherence to all COPPA rules and regulations
Privacy Contact
Privacy Officer Toluna USA 21 River road
Wilton, Connecticut 06897
privacyna@toluna.com

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