SHG Privacy Notice

Last Updated: January 2023

Universal Survey Center, Inc., d/b/a Survey Healthcare Global (SHG), has adopted this Privacy Notice (“Notice”) to establish and maintain an adequate level of Personal Data privacy protection. This Notice applies to the processing of Personal Data that SHG obtains from its Customers or individual respondents that are not member of the SHG Healthcare Community.

If you are a member of the OpinionSite Community and you would like to access the Privacy Notice, please click here:

OpinionSite Health:  https://healthcare.opinionsite.com/

OpinionSite Consumer:  http://consumer.opinionsite.com/

Please use the below drop-down menu to select the Privacy Notice applicable to you:

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+ Privacy Notice General

+ Privacy Notice for EEA, UK and Swiss residents

+ Privacy Notice for California

+ Privacy Notice for Virginia residents

Translations:

• Datenschutzerklärung (Deutsch)
• Declaración de privacidad de InCrowd (español)
• Politique de confidentialité d’InCrowd (français)
• Informativa sulla privacy di InCrowd (italiano)

Privacy Notice General

1. Controller of the Persona Data:

Universal Survey Center, Inc., d/b/a Survey Healthcare Global (SHG)

140 Sherman Street, 5th Floor

Fairfield, CT 06824

SHG Data Protection Contact & DPO:  [email protected]

• SCOPE

This Notice applies to the processing of Personal Data that SHG transfers to and stores in the United States.

We’re committed helping you understand how we manage and protect the information we collect. We take privacy seriously and have taken many steps to help safeguard the information we collect from you.

• PERSONAL DATA THAT WE COLLECT

SHG provides research solutions to its Clients, which are predominantly business customers, and individuals that may purchase products or participate to market research activities.

• General Data: SHG collects Personal Data from Clients and individuals when they purchase our products, supply research support services, register with our website, request information from us and participate to market research activities.
  • Communication Data: SHG may process information contained in or relating to any communication that you send to us or that we send to you. The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
  • Usage data: SHG may process data about your use of our website and services. The usage data may include your IP address, geographical location, browser type, version and language, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. We may also collect and process data on the websites you visited before our sites may be logged automatically if you are redirected to our site from our advertising campaigns. The source of the usage data is our analytics tracking system, marketing automation platform or other marketing technologies.
  • Market Research data: SHG might also collect personal data and anonymized and/or pseudonymized data produced by individuals’ participation to market research activities.
  • Information collected: The Personal Data that we collect may vary based on your interaction with SHG. As a general matter, SHG collects the following types of Personal Data:

Data collected from Companies and business entities:

Data collected from individuals:

SHG processes Personal Data that it collects directly from its clients or individuals and indirectly in its role as a service provider for the following business purposes:

• Operations: maintaining and supporting our products as well as delivering and providing the requested products/services;
  • Contractual; complying with contractual obligations related thereto (including managing transactions, reporting, invoices and other operations related to providing/receiving services to/from clients and individuals). This may include data included in Category A;
  • Market Research: Allowing individuals to participate in market research surveys and interviews and related activities. Report back to clients results in an anonymized and aggregated form.   
  • Publications: In certain occasions and strictly in accordance with your express instructions, we may process your personal data for the purposes of publishing such data on our website and elsewhere through our services.
  • Relationships and communications: Processing contact data for the purposes of managing our relationships and communicating with you (excluding communicating for the purposes of direct marketing) by email and/or telephone.
  • Direct marketing: Processing contact data for the purposes of creating, targeting and sending direct marketing communications by email and making contact by telephone for marketing-related purposes. We do this for promoting our business and communicating marketing messages and offers to our website visitors.
  • Research and analysis: Processing usage data for the purposes of researching and analyzing the use of our website, for example monitoring, supporting, improving and securing our website, services and business generally. SHG has a legitimate interest in maintaining security conditions on our websites to prevent malware, or other types of attacks. security is essential to protect the personal data of customers and visitors.
  • Record keeping: Processing your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records in servers located in the United State. We do this to ensure that we have access to all the information we need to run our business properly and efficiently in accordance with this Notice.
  • Legal compliance and vital interests: Processing your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
  • Required by Law: for other business-related purposes permitted or required under applicable local law and regulation for example satisfying governmental reporting, tax, crime investigation and national security; and (7) as otherwise required by law). This may include data included in Category A
  • In general: as requested by the clients and individuals;

• LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA

SHG uses the below legal bases for processing your data in relation with the above identified purposes:

• SPECIAL CATEGORY OF PERSONAL DATA OR SENSITIVE DATA
  • SHG might process certain categories of data that can be considered very sensitive. This data may be collected when individuals participate in market research activities carried out by SHG directly or on behalf of their clients. We are committed to handle this data with extreme care and only few authorized people have access to it. Such data might include: information about your health, your ethnic origin, biometric data, trade union membership, etc. Where we process special categories of personal data, “Sensitive Personal Data,” we will always obtain your explicit consent to those activities unless:
    • Consent is not required by law;
    • To protect your vital interests where you are incapable of giving your consent;
    • For the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity;
    • Processing is necessary for reasons of public interest in the area of public health as required by the local law. 
  • Where this is allowed by law, you might have the right to withdraw that consent at any time.

• AUTOMATED DECISIONS

• We reserve the right to make automated decisions, including using machine learning algorithms about website visitors in order to optimize and provide better experience when navigating our websites. Only digital data as specified in section VIII are included in this processing.
  • We might analyze your participation to our surveys with the purpose to enrich the profiling data we hold about yourself. The profiling data that we have collected might be used for making manual or automated decisions that involve your participation to market research activities. As results of this processing, we will be able to send you market research activities within your sphere of expertise and interest.
  • You may contact us if you would like any clarifications about the automated decisions.

• DIGITAL DATA
  • Cookies: SHG may set and use cookies to enhance your user experience on the sites, such as retaining your personal settings and preferences.  You may set your browser to prevent or reject cookies, or you may manually delete any cookies set. If you reject the cookies on the sites, you may still be able to use the sites, but they shall be limited to certain minimal functionality. From time to time SHG may use third-party tracking utilities that use session ID cookies that track site usability and assist SHG in improving user experience. This Privacy Notice does not cover the use of cookies by our third party providers as we do not have access or control over these cookies. We may collect information on our sites or in our emails using web beacons and or tracking pixels (electronic images). We may use beacons to count visits, understand usage and campaign effectiveness and to tell if an email has been opened and acted upon. You can review the cookies used by SHG’s website here.
  • Trend Analyses: SHG may use IP addresses to analyze trends, administer the Sites, to track your movement within the Sites, and to gather broad demographic information for aggregate use.
  • Links to other sites: our sites include links to other websites whose privacy practices may differ from SHG’s. If you submit personal data to any of those sites, your information is governed by the privacy statements of those third-party sites.
  • Managing cookies: Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

https://support.google.com/chrome/answer/95647 (Chrome);

https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);

https://help.opera.com/en/latest/security-and-privacy/ (Opera);

https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies            (Internet Explorer);

https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari);

https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).

• CHOICE WITH RESPECT TO USES AND DISCLOSURES OF PERSONAL DATA
  • SHG recognizes that individuals have the right to limit the use and disclosure of their Personal Data, and we are committed to respect those rights.  We offer individuals the opportunity to opt out of disclosures of Personal Data to a third party or the use of Personal Data for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individual.  We apply a strict policy with respect to disclosures of Sensitive Data including, when applicable, obtaining the explicit consent (i.e., opt in consent) of an individual prior to disclosing Sensitive Data to a third party or using Sensitive Data for purposes other than those for which it was originally collected or subsequently authorized by the individual.

1.  DISCLOSURE/TRANSFER OF INFORMATION FOR A BUSINESS PURPOSE
   1. SHG may disclose your Personal Information to a third party for a business purpose. We do this by entering into a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract. Furthermore, third parties must comply with data protection laws and agree to provide adequate protections that are no less protective than those set out in this Notice.

1. Disclosure: We may disclose your Personal Information for a business purpose to the following categories of third parties:Our affiliates and subsidiariesOur clients or their agentsService Providers and consultantsProfessional services organizations, such as auditors and law firmsOur business partnersInternet service providersGovernment entitiesOperating systems and platformsSurvey hosting providers Validation providers Rewards fulfillment providers SMS and video conference service providersCustomer and panel support services Credit card processorTax authorities
   1. Purposes of disclosure: SHG may disclose your personal information for the below purposes:
      1. Survey reporting
      1. Email services
      1. Authentication of medical licenses
      1. Identity verification of the panel members
      1. Offering and providing customer support
      1. Internal marketing campaigns for communicating new offers to our clients
      1. Internal marketing campaigns for improving and facilitating participation of Panel Members in market research activities
      1. Internal marketing engagement e.g. newsletters 
      1. Honorarium processing and fulfillment
      1. Auditing purposes and governmental reporting
      1. Tax reporting
      1. Allowing participation in market research activities
      1. For complying with your requests or contract obligation we have with you
   1. Disclosures due to acquisition or merge: We may share your information in connection with a merger, sale of company assets, financing or acquisition of all or a portion of our business to another company, if any. In this event, SHG will notify you before information about you is transferred and becomes subject to a different privacy policy.
   1. Anonymous information: We may also share aggregated or anonymous information that does not directly identify you. SHG may share anonymized aggregated demographic information with SHG partners.
   1. Other forms of disclosures: SHG also may disclose your personal data for other purposes or to other third parties when you have consented to or requested such disclosure or under the following circumstances:
      1. We respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;
      1. We believe it is necessary to share information in order to investigate or prevent fraud, or to take action regarding illegal activities, situations involving potential threats to the physical safety of any person, or as otherwise required by law.
      1. We transfer information about you if SHG is acquired by or merged with another company. In this event, SHG will notify you before information about you is transferred and becomes subject to a different privacy notice.
      1. In response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
   1. Third party compliance: Such third parties must agree to use such Personal Data only for the purposes for which they have been engaged by SHG and they must either:
      1. Comply with the data protection laws, Privacy Shield principles, or another safe and secure mechanism that provides high level of protection.; or
      1. Agree to provide adequate protections for the Personal Data that are no less protective than those set out in this Notice.
   1. Liability: SHG is potentially liable in cases of onward transfers of Personal Data to third parties, such as when third parties that act as agents on our behalf process Personal Data in a manner inconsistent with applicable data protection regulations.

1. TRANSFER PERSONAL DATA OUTSIDE YOUR COUNTRY OF RESIDENCE
   1. The third parties as described in paragraph X might be based in US or in other countries. In these instances, SHG imposes strict contractual obligations to third parties to maintain a level of protection that is equal to the protection offered by this notice.
   1. In other instances, we may ask your consent to allow us to transfer your personal data into another country. In doing so we will provide you with full information about the transfer.
   1. You may contact our DPO if you would like to know more about our international transfer assessment and/or copy of the transfer mechanism that we use for sharing your Personal Data outside your country of residence. 

1. ANTI-SPAM
   1. SHG maintains a strict “No-Spam” policy, which means that SHG does not intend to sell, rent or otherwise give your email address to a third-party without your consent.

1. DATA INTEGRITY, PURPOSE LIMITATION AND RETENTION
   1. SHG will not process Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you.  To that end, SHG will take reasonable steps to ensure that your Personal Data is reliable for its intended use, accurate, complete, and current.  SHG uses reasonable efforts to maintain the accuracy and integrity of your Personal Data and to update it as appropriate.
   1. We retain your personal data as follow:
      1. Contact data will be retained for a minimum period of 2 years following the date of the most recent contact between you and us, or until an updating information request or removal request is made by you;
      1. Communication data will be retained for a minimum period of 2 years following the date of the communication in question or until a removal request is made by you;
      1. Usage data will be retained for a minimum period of 2 years or until a removal request is made by you  following the date of collection;
      1. In general we do not retain your personal data for more than 2 years since your last engagement/interaction with the Company;
   1. We may retain your information as necessary (including a longer period) to comply with our legal obligations, resolve disputes and enforce our agreements.

1. YOUR RIGHTS
   1. You have the right to obtain confirmation about whether your personal data is included in our databases.  Upon request, SHG will provide an individual access to your personal data within the time frame dictated by the applicable data protection regulations. SHG will allow you to know what Personal Data is included in our databases and to ensure that such Personal Data is accurate and relevant for the purposes for which SHG collected the Personal Data. You may also request a copy of your data in a commonly used and machine-readable form.
   1. You may review your own Personal Data stored in the databases and correct, update, modify, or delete any data that is incorrect or incomplete.
   1. You may request to have the personal information that we have about you to be deleted from our servers. SHG will take reasonable steps, including technical measures, to comply with your request.
   1. You may request the Personal Data you provided to us in a commonly used and machine-readable form.
   1. You have the right to withdraw your consent at any time, without affecting the lawfulness of our processing based on such consent before it was withdrawn, including processing related to existing contracts for our Services.
   1. these rights are subject to certain limitations and exceptions including, but not limited to, when the burden or expense of providing this access would be disproportionate to the risks to your privacy in the case in question, or where the rights of persons other than you would be violated by the provision of such access.  If we determine that your access should be restricted in a particular instance, we will provide you with an explanation of our determination and respond to any inquiries you may have.

1. HOW TO EXERCISE YOUR RIGHTS
   1. You can exercise your rights by filling out the form found at http://preferences.surveyhealthcareglobal.com/privacy. You may also submit a request at [email protected], reach us on toll free number 800-470-8213 or via postal mail at SHG, Attn: Privacy Department, 140 Sherman Street, 5th Floor, Fairfield, CT 06824 USA

1. RESPONSE TIMING AND FORMAT
   1. We endeavor to respond to a verifiable request within 30 days of its receipt.  If we require more time (up to two extra months), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a verifiable request, if applicable.
   1. We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
   1. Request that we can’t process: We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. Making a verifiable request does not require you to create an account with us.  We will only use Personal Information provided in a verifiable request to verify your identity or authority to make the request.
   1. Requests for Personal Data: SHG will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise:
      1. legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or
      1. requests received from the Data Subject.

1. RESPONSIBILITIES AND MANAGEMENT
   1. SHG has designated the Privacy & Compliance Department to oversee its information security program, including its compliance with the Privacy Shield program and the GDPR and any other applicable Privacy Law. The Privacy & Compliance Department shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Notice also may be directed to [email protected].

Privacy Notice for EEA, UK and Swiss Residents

(Included in a different document)

California & Virginia Residents

Included in a different document