BOUNCE INSIGHTS – USER PRIVACY STATEMENT:

Version: 6

Last updated: 6th January 2023 

WHO WE ARE:

Bounce Marketing Ltd. (“Bounce Insights” “Company”, “we,” “us” or “our”) is an Irish company based in Dublin, Ireland. Bounce Insights is a consumer insights platform that aims to bring companies closer to their desired consumers, by allowing individuals who sign up to use our service (our “User” or “Users”) to respond to real-time questions and queries through targeted surveys, discussion boards, focus groups and other related research projects in return for a cash reward or other incentive. Bounce Insights is committed to preserving User rights under data protection legislation, specifically the Data Protection Act 2018 and the EU General Data Protection Regulation (“GDPR”). All references in this Privacy Statement to Bounce Insights include Bounce Insights and its subsidiary and affiliated companies.

Bounce Insights are a data controller when processing your data as a User on www.bounceinsights.com or the Bounce Insights Mobile Application.

INTRODUCTION:

Bounce Insights take data protection compliance seriously. This Privacy Statement explains how we use and protect the information of our Users. It applies to the personal data which you provide to us when you visit www.bounceinsights.com or participate in any Bounce Insights panel or subpanel (“Panel”) or download and install the Bounce Insights Mobile Application. This Statement covers data collected on our Site and Service using surveys, discussion boards, focus groups, video, text, and images. We may also receive information about you from our third-party service providers.

This Statement describes the processing of personal data and other information by Bounce Insights in connection with Bounce Insight’s services (as defined herein), from Users and Users of our clients. Bounce Insights’ services provide you with the opportunity to join a Panel (as defined herein), participate in surveys, discussion boards, focus groups and other research projects (whether as a Panel member or a non-Panel member), use the websites associated with the Panels, download and use the Bounce Insights Mobile Application, and receive and redeem rewards and incentives, including, without limitation, cash rewards, discounts and gift cards, offered in connection with Panel membership and/or the completion of surveys (collectively “Services”). Registration with, use of, and access to Bounce Insights’ Services and the Bounce Insights Mobile Application are subject to Bounce Insights’ Terms and Conditions. 

Your use of Bounce Insights’ Services is completely voluntary and therefore Bounce Insights processing of your personal data in connection with the Services and this Statement is subject to your consent and acceptance of our Terms and Conditions. For clarification, except for Panels that have a separate privacy policy, this Statement applies to all of Bounce Insights’ survey research Panels, including, without limitation, Bounce Insights’ proprietary panels and any online Panels we create and conduct on behalf of our corporate clients (each a “Panel” and collectively the “Panels”).

This Statement does not cover, and we are not responsible for, the privacy, data, or other practices of any third parties (except as required by applicable law), such as our corporate clients and any service providers. Our clients create online research communities through which they collect information from their users and use the data in accordance with their terms. If you have questions about a particular online community, please contact the creator of the online community. 

INFORMATION YOU PROVIDE:

We collect personal data from Panel members during and after registration, including, without limitation, during participation in a survey and in connection with the receipt and redemption of rewards and incentives. Information may be collected in various ways, including inquiry forms, registration forms, surveys, and contests. Bounce Insights collects additional data included in your member profile which you submit voluntarily.

If you use ‘Social Media’ to sign up or ‘Log in’, such as Facebook, Instagram, Twitter, or any Third-Party Social Network Account, they may share some of the information that you have provided to them with us. When you participate in surveys, you may be asked for your personal opinions, as well as demographic information, such as your age, type of job, and household composition.

We also collect your telephone number and copies of your correspondence with us (including email addresses and phone numbers) if you contact us. This allows us to facilitate your use of the Services.

When you redeem rewards, we will ask you to provide us with additional information in order to transfer rewards to your PayPal/Revolut account or initiate similar payment transfers through Stripe Payments or similar technologies. The information requested can include: PayPal email address, bank account holder’s name, bank account number, Revolut account phone number, bank routing number, and bank account type. Details of transactions you carry out through the App and of the fulfilment of gift cards or PayPal payments will also be collected. If you earn more than a certain amount of money on Bounce Insights, we may be required by law to mail you a form to obtain your social security number, and send you a form with your name, social security number, and the amount of money we have paid you for government tax reporting purposes.

In order to provide high quality service and to protect our members and the Website, we take steps to make sure that Bounce Insights members provide honest and accurate information about themselves and to all survey questions to the best of their ability. These steps may include sending you a text message or email to confirm your contact information or asking you to provide personal information through security questions to help us verify your identity before you can redeem your points for rewards. Please contact support if you have any questions – support@bounceinsights.com.

LEGAL BASES FOR PROCESSING YOUR DATA: 

We rely on the following legal bases to process your personal information under the GDPR;

• Article 6(1)(b) GDPR: The data subject has given consent to the processing of their data for one or more specific purposes  
• Article 6(1)(f) GDPR: Processing is necessary for the purposes of our legitimate interests

Where we rely on legitimate interests to process your personal data, we have carried out a Legitimate Interests Assessment to ensure those interests are valid.

We do not process special categories of personal data (sensitive data) as set out under Article 9 GDPR. However, if we do decide to process special category data, this will always be done on the basis of your explicit consent under the GDPR;

• Article 9(2)(a) GDPR: The data subject has given explicit consent to the processing of their personal data for one or more specific purposes.

INFORMATION COLLECTED THROUGH COOKIES AND OTHER TRACKING TECHNOLOGIES:

We may also collect certain information automatically, such as information about:

• your device or computer and its capabilities, including, but not limited to, the operating system, IP address, device carrier, device type, time zone, network status, browser type, browser identifier, location, and other information that alone or in combination may be used to uniquely identify your device or computer; and
• your activities and interactions with Bounce Insights Services, including, without limitation, survey data and responses, and reward, incentive, and/or sweepstakes information. 

We use this information to:

• assist in providing support to you should you have difficulty accessing or completing a survey.
• ensure that the survey is delivered in a form suited to the software your computer or mobile device is using.
• identify suitable partner survey opportunities.
• determine the source of mobile application installs and to establish advertising effectiveness. 

For more information on our use of cookies, pixel trackers, and other deployed technologies to collect personal data for these purposes, please view our Cookie Policy.

HOW WE USE YOUR INFORMATION:

In addition to other purposes set forth in this Statement, we and our third-party service providers use your personal information (such as name, phone number and email address) collected through Bounce Insights Services and the Bounce Insights Mobile Application to: 

• Respond to your inquiries and fulfil your requests
• Send administrative information to you
• Communicate with you regarding your account and membership with a Panel
• Provide access to and use of the Services
• Communicate with you regarding your participation in a survey(s)
• Append information about you to your responses for any surveys you participate in, such as geographical location or age to produce anonymous research results
• Pass your individual survey responses together with your personal information to the client who commissioned the survey, with your explicit consent when asked in a survey
• Tailor survey opportunities to you
• Send you notifications of survey opportunities based on your location and/or the information you provided to us
• Invite you to participate in partner surveys in which your participation is optional. By participating in such partner surveys, you are providing your responses directly to the client who commissioned the survey
• Identify suitable partner survey opportunities based on what you have told us about yourself by sharing your individual survey responses and/or geographical location with our partners
• Identify suitable partner survey opportunities based on information about the device you are using to access our mobile applications and website
• Comply with all legal obligations, including, without limitation, tax obligations 
• Administer and manage our reward and incentive programs and fulfil your requests for rewards and incentives
• Update our records
• Identify whether you are complying with our terms of service
• Comply with any data suppression obligations or requirements
• Verify your identity and for fraud detection and/or prevention purposes; and 
• As otherwise permitted under this Statement or as otherwise authorised by you.

We and our third-party service providers may use other information from the Services that is linked or reasonably linked to a particular computer or device to:

• Operate, improve, analyse, and manage the Services, including improve the user experience
• Ensure the Services function properly
• Track your use of the Services to improve the design, functionality, and effectiveness of the Services
• Measure and report on the success of advertising and marketing campaigns and content
• Understand users’ navigation behaviour
• Understand opportunities to develop new product
• Diagnose server problems, administer the Services via your IP Address (a number automatically assigned to the computer or device that you are using by your internet service provider) and ensure the technical functioning of the Services
• Provide you with personalised location-based services and content using your device’s physical location (where permitted by law) and
• As we believe to be necessary or appropriate:
  • under applicable law;
  • to comply with legal process and our legal obligations;
  • to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties;
  • to enforce our Terms and Conditions;
  • to protect our operations;
  • to protect our rights, privacy, safety or property, and/or that of you or others;
  • to allow us to pursue available remedies or limit the damages that we may sustain; and
  • to prevent or stop activity we may consider to be, or to pose a risk of being, fraudulent, illegal, unethical, or legally actionable activity, including abuse of our Services’ infrastructure or the Internet in general (such as spamming, denial of service attacks, or attempts to compromise the security of information, among other things)

In some instances, we may combine information from the Services that is linked or reasonably linked to a particular computer or device with personal information. If we combine such information with personal information, the combined information will be treated by us as personal information as long as it is combined.

HOW LONG WE KEEP YOUR DATA:

We will only store your data for as long as it is necessary for the fulfilment of contracts with our clients, or for the fulfilment of survey opportunities that users have willingly agreed to in our Terms and Conditions when registering for our application. We will only store data that is necessary for these survey opportunities, in the form of targeting criteria for our survey clients.

ACCOUNT EXPIRATION:

Your account is deemed inactive if you do not login for a period of 6 months. Once your account is deemed inactive, we will send you an email reminding you to login within the next 2 weeks if you want to continue using your account. If you do not login within those 2 weeks, your account will be deleted.

COMMUNICATIONS YOU WILL RECEIVE:

When you register to our site, you will be prompted to enter your email address. Our sales team will then contact you to help you get started on our platform. To ensure you are getting the most out of the platform, we will send you emails that will help familiarise you with our platform, provide support, and to get you fully set up. We do not send any marketing communications to you via email unless you opt-in to receive that content.

We may contact you to communicate with you as follows via email communications or other similar communication methods for the purpose of:

• sending you survey invitations
• communicating with you regarding your survey participation (past, present and/or future)
• communicating with you regarding reward or incentive information, inquiries, and redemption
• communicating with you regarding potential promotions
• sending you notices required to be provided under this Statement or required by law
• responding to inquiries received from you, and
• sending you communications to confirm your identity and for fraud detection and prevention purposes.

By agreeing to become a Panel member, you agree to receive invitations to participate in surveys. You may unsubscribe from Panel membership at any time, see “Questions Or Complaints Or Opting Out:” below. 

HOW WE SHARE PERSONAL INFORMATION AND AGGREGATE INFORMATION COLLECTED WITH THIRD PARTIES:

We may disclose personal information (such as name, phone number and email address) and aggregate information collected to third parties as follows:

• With your consent, as agreed when registering for the Bounce Insights’ Mobile Application, and through the details provided in this Statement
• With the particular client for whom we have collected your personal information through our Services, including but not limited to online Panels we create and conduct on behalf of our corporate clients using our Services
• Under applicable law or in response to a subpoena or an order of a court or government agency
• To establish, exercise, or defend legal claims of an individual or Bounce Insights
• To establish or exercise our legal rights
• If we believe disclosure is necessary to investigate, prevent, or take action regarding illegal activity, suspected fraud or other wrongdoing
• To protect and defend the rights, property, or safety of our company, our employees, our users, or others; or to enforce Panel terms of use or other agreements or policies
• In connection with a corporate change such as a merger, our acquisition by another company, or a partial or total sale of our assets
• To authorised third-party agents and/or vendors and subcontractors and clients, partners, who are providing services, including, without limitation, data append services, data validation services, fraud detection and/or prevention services, database-matching services, coding services, data segmentation services, and reward, and incentive related services, as well as market research partners that provide surveys
• Your information may be shared with third parties in aggregate form. Aggregated data does not include personally identifiable information. This means that your survey responses may be combined with the responses of others who participate in surveys and those gathered responses are reported to the third party that commissioned the study. You will not be identified from this information.
• Identifying third party survey opportunities for you, facilitating your participation in a third-party survey(s), tracking your survey activity, addressing survey quality issues, & incentive and reward fulfilment from completing third party surveys.
• As otherwise permitted under this Statement.

We and our third-party service providers may share other information from the Services that is linked or reasonably linked to a particular computer or device:

• Among our affiliates for the purposes described in this Statement (Bounce Insights is the party responsible for the management of the information jointly used by it and its affiliates)
• With our clients to allow them to analyse the effectiveness and performance of our Services
• With our third-party service providers who provide services that enhance our Services, including cloud storage vendors, marketing, analytics, and other services
• With a third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings)
• As we believe to be necessary or appropriate:
  • under applicable law
  • to comply with legal process and our legal obligations
  • to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties
  • to enforce our Terms and Conditions
  • to protect our operations
  • to protect our rights, privacy, safety or property, and/or that of you or others
  • to allow us to pursue available remedies or limit the damages that we may sustain; and
  • to prevent or stop activity we may consider to be, or to pose a risk of being, fraudulent, illegal, unethical or legally actionable activity, including abuse of our Services’ infrastructure or the Internet in general (such as spamming, denial of service attacks, or attempts to compromise the security of information, among other things).

We may also share and disclose other information that we collect, including aggregate information, as we consider necessary to develop and provide our Services, including in the ways described above in this section.

There may be areas of the Services (e.g., message boards, discussion rooms, and other online forums) in which you are able to post information that will be available to all other users of the Services. By choosing to use these areas, you understand and agree that anyone may access, use, and disclose any information that you post to those areas and as such, immediately upon posting, the materials or information you post shall be considered public information.

INTERNATIONAL DATA TRANSFERS:

As some of our third parties may reside outside of the European Union (EU)/European Economic Area (EEA), your personal data may be transferred, processed, and stored outside of the country in which you reside, including the United States. Where we transfer your data outside the EEA, we ensure to enter Standard Contractual Clauses or other similar safeguards with those third parties to protect any personal data shared. We will also carry out Transfer Impact Assessments for international data transfers, where required to do so.

LINKS TO THIRD PARTY WEBSITES:

This Statement applies solely to the Services and this website, www.bounceinsights.com, and not to any other product or service. The Services and this website may contain links to certain third-party websites that we believe may offer services or useful information. In addition, when you navigate to a third-party survey website, you may be asked to provide information to that website. The policies and procedures we described here do not apply to those websites. We recommend that you carefully read the privacy policies of each site that you visit for information on their privacy, security, data collection and distribution policies. If you are unsure whether an app or website is controlled, affiliated, or managed by the Company, you should review the privacy policies at each linked app or website to determine how that site treats your personal information.

Because of the dynamic media capabilities of the App, it may not be clear which links are embedded in the App and which are embedded in third-party media and/or content. The Company cannot and does not guarantee the privacy policies and practices of any third party. The Company does not control, operate, or endorse any information, products, or services of any third-party apps or websites that may be reached through links from the App. Bounce Insights is providing these links only as a convenience to you. The use of any personal information provided by you to, or automatically collected from, a third party will be governed by that party’s privacy policies. 

HOW YOUR PRIVACY IS PROTECTED:

We use the latest security measures to protect against the loss, misuse, and alteration of data. Access to all user information is restricted. Web servers and databases are housed and maintained in secure locations and protected by firewalls. We pride ourselves on updating and maintaining our security and privacy practices to ensure that your personal information remains protected at all times.

SPECIAL NOTE ABOUT CHILDREN:

We adhere to applicable laws and industry codes pertaining to the protection of children’s privacy. Our Services are not designed or intended for use by any individual under the age of sixteen (16) and we do not knowingly collect personal data from anyone under the age of sixteen (16). If we become aware that we inadvertently collect personal data from anyone under this age threshold, we will promptly delete such personal data. Parents, guardians, or other persons with parental rights are encouraged to contact us, as set forth below, to discuss this Statement and their rights to access, review, correct, delete, or object to the processing of personal data of or about their child or children.

YOUR RIGHTS:

Under data protection legislation, you have certain rights regarding the data that we process in relation to you. These include:

Right to withdraw consent: individuals can withdraw consent to processing at any time. If you withdraw your consent to the use or sharing of your information for purposes set out in this Statement, you may not have access to all (or any) of our products or services, and we might not be able to provide you all (or any) of the products or services under this Statement. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so or if your consent was limited to certain processing activities.

Right to be informed: organisations must tell individuals what data is being collected, how it’s being used, how long it will be kept and whether it will be shared with any third parties. This Statement provides that information to you. If you require further information on how we process your personal data, please contact us at dataprotection@bounceinsights.com 

Right of access: individuals have the right to request a copy of the information that an organisation holds on them.

Right of rectification: you have the right to correct data that is inaccurate or incomplete.

Right to be forgotten: in certain circumstances, individuals can ask for the data an organisation holds on them to be erased from their records.  

Right of portability: individuals can request that an organisation transfer any data that it holds regarding them to another company.

Right to restrict processing: individuals can request that an organisation limits the way it uses personal data.

Right to object: individuals have the right to challenge certain types of processing, such as direct marketing.

Right related to automated decision-making including profiling: individuals are free to request a review of automated processing if they believe the rules aren’t being followed.

If you wish to exercise any of your above rights, please contact us at dataprotection@bounceinsights.com .

Your California Privacy Rights

California Civil Code Section 1798.83 permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at dataprotection@bounceinsights.com 

DATA PROTECTION COMMISSION:

If you are not satisfied with how we are processing your personal data, you have the right to lodge a complaint with the Office of the Data Protection Commission by clicking here. For more information on how to submit a complaint in writing or by telephone, please visit www.dataprotection.ie   

CONTACTING US FOR QUESTIONS OR COMPLAINTS OR OPTING OUT:

If you have any questions or complaints regarding our privacy practices or this Statement, or if you want to withdraw consent, or exercise your rights to access, review, correct, delete, or object to the processing of personal data please contact us using the below information.

Email:  dataprotection@bounceinsights.com 

Post:   39/40 Mount Street Upper, Dublin 2, Ireland, D02X7H6

Appendix A

1.     Authorised Sub-Processors