Greenberg, Inc. Privacy Notice


 

Our Commitment to Privacy

Greenberg, Inc. (“Greenberg” and “we”) is committed to protecting your Personal Data and your privacy. We endeavor to ensure that any Personal Data we collect about you (“Your Data”) is held and processed strictly in accordance with applicable data protection legislation. 

If you are resident in the EU (or a country that has adopted a local law to implement or adopt the GDPR) (“EU Residents”), this will include the European General Data Protection Regulation (“GDPR”) or any applicable local law implementing or adopting the GDPR (“Applicable Local Laws”). Please see the section “Additional Information for EU Residents” below for further information. Note that Greenberg is based in the United States and, by providing your Personal Data to Greenberg, you acknowledge that Your Data will be processed outside of the EEA.

In this Privacy Notice, the terms Personal Data, Data Controller and processing have the meanings given to them in the GDPR (which can be accessed here), unless otherwise indicated.

Identity and Contact Details

Greenberg, Inc. is the Data Controller of Your Data. You can contact us regarding this Privacy Notice or Your Data by emailing privacy@greenberginc.com. You may also contact us by post at:

Greenberg, Inc., Compliance Team
1250 53rd Street, Suite 5
Emeryville, CA 94608
United States

As Greenberg, Inc. is based in the United States, we have nominated Calligo to be our representative within the EU for the purposes of the GDPR. Calligo can be contacted at greenbergdpo@calligo.cloud.

If you are an EU Resident, please ensure Calligo is copied on any correspondence you send to us relating to the processing of Your Data. 

Scope

At Greenberg we collect and process Personal Data in a number of ways, so this notice is layered to allow you to find the information that is most relevant to your situation.

The Way We Retain Data

Unless otherwise indicated below, we only keep Your Data for the length of the specific research project for which it was obtained, plus a maximum of 12 months. We only retain the Personal Data beyond the length of the research project in order to allow the relevant client to raise further questions which we may be required to answer. 

Who We Share Information With 

It may be necessary for us to share Your Data with the following third parties and other parties indicated in the relevant section of the Privacy Notice, below:

  • Third party service providers. Greenberg uses third parties to provide certain data storage services, which may include storage of Your Data.

  • Consultants. Greenberg occasionally makes use of consultants in order to analyze responses to research programs.

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change occurs within our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Notice.

  • Where we are legally obliged to do so. Greenberg may be required to disclose personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

How to Access, Correct, or Delete Your Data (EU Residents)

You can request access to all the Personal Data that Greenberg has collected from you directly or indirectly by contacting us at privacy@greenberginc.com. We will process your request within 30 days. You may also contact us by post at:

Greenberg, Inc. Compliance Team
1250 53rd Street, Suite 5
Emeryville, CA 94608
United States

EU Residents have further rights in relation to their Personal Data. Should you wish to correct, delete, restrict or stop the processing of any of your Personal Data, please see the section “Additional Information for EU Residents” below.

Our Commitment to Data Security

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place certain physical, electronic, and managerial procedures to help safeguard the information we collect. Our corporate code of business ethics and conduct is our commitment to supporting the integrity and ethical standards we expect from our employees. The code encompasses how we expect employees to protect confidential information (including Your Data). We limit our employee access to your private information to specific research processes.

Requirement to Provide Personal Data

Individuals voluntarily provide their information at the onset of the research program and may limit the use and disclosure of their Personal Data by choosing not to participate.

Children

We do not collect personal information from any person we know to be an individual under the age of 18 without explicit parental or guardian consent. If you are under 18, please do not attempt to send us any Personal Data about yourself. 

How We Collect Your Data

At Greenberg, we collect and process Personal Data in a number of ways.  To help you find the information that is most relevant to your situation, we have separated our Notice into a number of sections:

  1. You are taking part in one of our online surveys or a panel survey, using a survey platform such as Decipher

  2. You are taking part in an interview, forum or focus group conducted by Greenberg

  3. You are taking part in a behavioral data survey

  4. You are using our website

  5. You are contacting us via email, post or telephone in relation to a matter not otherwise covered by this policy.

 

1. You Are Taking Part in One of Our Online Surveys or a Panel Survey, Using a Survey Platform Such as Decipher

Scope

This section of the Privacy Notice sets out how we collect Personal Data when you take part in one of our online surveys or when you take part in a panel survey using an online survey platform such as Decipher and what we do with that Personal Data. We will refer to the online surveys and panel surveys together as “Surveys”.  

In most instances, the information we collect through our Surveys is not Personal Data because we do not ask for, or have access to, your name or other information that would identify you as an individual. We use third party companies to select participants from their panel of members who have agreed to take part in Surveys like ours and those third parties do not provide us with your name or your contact details. The responses you give in our Surveys are not, therefore, linked to or associated with you in any way.  

It is, however, possible that during the course of the Survey, sufficient information is provided to allow you to be identified and some Personal Data may therefore be held by Greenberg. We endeavor to protect all of the information we gather about you as if it were Personal Data, as set out below.

The Information We Collect

Greenberg may collect a wide range of personal information, depending on the nature of the market research and strategy program (“Research Program”) in which you have voluntarily chosen to participate. Only the information necessary for the particular Research Program is collected and this could include information such as your opinions about a particular product or service provider.

In addition, we may also collect certain screening information such as your age, gender, zip code and range of income level (“Screening Data”).

In certain circumstances, where the Research Program requires it, we may also ask for information that is considered “special category data” under the GDPR, such as your ethnicity, political opinions, religious or philosophical beliefs and sexual orientation. In these cases, you will always be given the option of not responding to the question, so providing such information is entirely voluntary. Note that by providing special category data, you are consenting to it being used in accordance with this policy. 

As set out above, we take steps to ensure that all Screening Data and the data gathered during the Survey is not kept with, or in any way linked to, your name or other personal identifier.

We may also offer participants the option to provide their name and email address in order to be entered into a prize draw after completing a Survey. If you are a winner of a sweepstake or prize draw, you will receive the prize via email in accordance with the rules and regulations of the sweepstake in place.

How We Collect Information

We collect information directly from you through your voluntary responses to our screening questions and Survey questions.

We may also obtain Personal Data directly from you when you voluntarily choose to provide it to us in order to take part in a prize draw.

We might collect information about you from the third party sample provider who sends you the link to our Survey, or from our partners who may have sponsored the Survey.

The Way We Use Information

We use the data gathered in our Surveys (“Survey Data”) to create an anonymized, high-level market research report for our client (who has commissioned the Research Program) based on the overall findings from our Research Program. We do not name participants in our reports or link our results to individual participants. 

We use the Screening Data in order to assess whether you are eligible to participate in our Survey.

If you have provided your name and email address in order to take part in a prize draw, we will use that data to contact you in the event that you win the prize draw.

For EU Residents, please see “Additional Information for EU Residents,” below, for information about how you can withdraw your consent.

Who We Share Information With

We use a third party software platform, Decipher, to collect and store Survey Data. As a result, Decipher has limited access to Your Data.  In certain circumstances, we may also use selected third parties to conduct Surveys on our behalf who may also have limited access to Your Data. We require all such third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

How Long We Retain Information For

For any category of documents not specifically defined elsewhere in this Policy, and unless otherwise mandated by applicable law, the required retention period for such information will be deemed to be 12 months from the start of the project.

As an exemption, retention periods within the Data Retention Schedule can be prolonged in cases such as:

  • Ongoing investigations by Member State authorities, if there is a chance that records of Personal Data are needed by Greenberg to prove compliance with any legal requirements; or

  • When exercising legal rights in cases of lawsuits or similar court proceedings recognized under local law.

2. You Are Taking Part in an Interview, Forum or Focus Group Conducted by Greenberg

Scope

This section of the Privacy Notice sets out how we collect Personal Data when you take part in any one of the following studies that we conduct, or that a third party conducts on our behalf, and what we do with that Personal Data: 

  • An in-depth or expert interview (whether by telephone, video or in person)

  • An online forum

  • A pre-assignment study (whether remotely or in person)

  • A focus group (whether remotely or in person)

  • A workshop

  • An ethnographic study (where we visit you in your home or offices or some other location to observe and listen in a non-directed way).

We will refer to these collectively as “Interviews”.

The Information We Collect 

During the recruitment stage of an Interview, we will collect your first name, last name, your email address, home or work address and telephone number. Depending on the nature of the market research and strategy program (“Research Program”) in which you have agreed to participate, we may also collect your public social media page address, your job title and your industry. 

During the screening phase, we will collect information necessary to establish whether you qualify for the relevant Research Program, which may include information such as your age, gender, zip code and range of income level.

During the Interview, Greenberg may collect a wide range of Personal Data, depending on the nature of the Research Program. We aim to collect only the information necessary for the particular Research Program, which could include information such as your opinions about a particular product or service provider. However, given the open-ended nature of the Interviews, this may include further Personal Data that you volunteer during the Interview and some of this information may include information that is considered “special category data” under the GDPR, such as your ethnicity, political opinions, religious or philosophical beliefs and sexual orientation. Note that by providing special category data, you are consenting to it being used in accordance with this policy.   

When we enter into a non-disclosure agreement with you, we also collect certain information necessary to complete and perform the contract, such as your full name, postal address, email address and signature.

How We Collect Information

We collect information directly from you through your voluntary responses to our screening questions and Interview questions. 

In some instances, we may collect Personal Data from third party sources such as publicly available websites (for example, respondent.io) or social media websites and forums. We may also receive some Personal Data about you from our client or, if you have agreed to be on a third party’s database in order to receive invitations to participate in research, we may receive some information about you from that third party.

If the Interview is being conducted by a third party on our behalf, that third party will provide us with the Personal Data about you that we have asked them to collect.

The Way We Use Information

We use the Personal Data that we gather about you during the recruitment stage to contact you about the Interview. Our legal basis for using Your Data in this way is that it is necessary for our legitimate interest of conducting Interviews in which you have indicated you would like to participate. 

We use the responses that you provide to our screening questions (“Screening Data”) in order to assess whether you are eligible to participate in our Interview. We may also use some of this information in our client report.

For the purposes of the GDPR, our legal basis for using Your Data in this way is consent. If you are an EU Resident, we request that you indicate your consent prior to answering our screening questions and, by doing so, and by voluntarily providing your responses to our questions, you are consenting to Greenberg using Your Data as set out in this Privacy Notice. For EU Residents, please see the “Additional Information for EU Residents,” below, for information about how you can withdraw your consent. 

We use the information that you provide during the Interview (“Interview Data”) to build findings and insights in order create a market research report for our client which may be in the form of a video or audio compilation, written report or transcript from an audio or video file.

For the purposes of the GDPR our legal basis for using Your Data in this way is consent. If you are an EU Resident, we request that you indicate your consent prior to taking part in the Interview. We may also include Interview Data in our client proposals, where you have consented to us doing so.  

Who We Share Information With

On occasion, we may share your Screening Data with the client who has commissioned the Research Program. We may also share your Interview Data with that client.

We may also share certain Personal Data with selected third party recruiters that we have asked to conduct recruitment or screening on our behalf, or third party interviewers that we have asked to conduct Interviews on our behalf. We require all such third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third party service providers to use your Personal Data for their own purposes and we only permit them to process your Personal Data for specified purposes and in accordance with our instructions. 

How Long We Retain Information For 

For any category of documents not specifically defined elsewhere in this Policy, and unless otherwise mandated by applicable law, the retention period required for such information will be deemed to be 12 months from the start of the project.

As an exemption, retention periods within the Data Retention Schedule can be prolonged in cases such as:

  • Ongoing investigations by Member State authorities, if there is a chance that records of Personal Data are needed by Greenberg to prove:

    • Compliance with any legal requirements; or

    • When exercising legal rights in cases of lawsuits or similar court proceedings recognized under local law.

3. You Are Taking Part in a Behavioral Data Survey

This section of the Privacy Notice sets out how we collect Personal Data when you download a behavioral data application that tracks your internet searches and the content you view on certain websites and applications (“App”) and what we do with that Personal Data.

In most instances, the information we collect through the App is not Personal Data because we do not ask for, or have access to, your name or other information that would identify you as an individual. We use third party companies to select participants from their panel of members who have agreed to download the App and those third parties do not provide us with your name or your contact details.

It is, however, possible that the App may gather sufficient information to allow you to be identified and some of your Personal Data may therefore be held by Greenberg. We endeavor to protect all of the information we gather about you as if it were Personal Data, as set out below.

The Information We Collect 

The App does not actively collect any Personal Data. However, it is possible that Greenberg may inadvertently collect Personal Data such as your name, email address, postal address or telephone number, if this information is input into a website while the website is being tracked by the App.

How We Collect Information

The data collected by the App is downloaded by the third party sample provider who has asked you to install the App. The third party sample provider sends us some of this App data. 

The Way We Use Information

We analyze the data gathered from the App and use it to create an anonymized, high-level market research report for our client (who has commissioned the Research Program) based on the overall findings from that data. We do not name participants in our reports or link our results to individual participants. We do not use any Personal Data inadvertently gathered by the App in our reports.

The legal basis for Greenberg using the Personal Data, as set out above, is that you have given your consent to us doing so. We request that you indicate your consent prior to downloading the App and, by doing so, you are consenting to Greenberg using Your Data as set out in this Policy.

For EU Residents, please see the “Additional Information for EU Residents,” below, for information about how you can withdraw your consent.

Who We Share Information With

We do not share Your Data with any third parties other than those set out in the General Information section, above.

How Long We Retain Information For

We delete any Personal Data collected by the App as soon as we complete our market research report for our client.

 

4. You Are Using Our Website 

Scope

This section of the Privacy Notice sets out how we collect Personal Data when you visit our website, greenberginc.com, and what we do with that Personal Data. It does not cover the Personal Data collected when you contact us using the postal, email or telephone details displayed on our website, as this is covered under Section 5, below.

Using the “Get In Touch” Form

When you use the “Get In Touch” form on our website, we collect your first and last name, your company name, your email address and any other Personal Data you voluntarily submit in your message. 

We use this Personal Data to respond to your query or request and our legal basis for using Your Data in this way is that it is necessary for the purposes of our legitimate interests of running our business and increasing our customer base.

We may also use this Personal Data to send you marketing materials, but only where you have consented to us doing so by ticking the opt-in box at the bottom of the form. For EU Residents, please see the “Additional Information for EU Residents,” below, for information on how you can withdraw your consent.

We share the information you submit using the “Get In Touch” form with the third party service provider who hosts our website, but only to the extent necessary to provide the service.

We keep the information you submit through the “Get In Touch” form for as long as is necessary to resolve your query or respond to your request. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation.

Commenting on a Blog on Our Website

When you submit a comment on a blog on our website, we will collect and store any Personal Data that you voluntarily submit in your comment. Your comment, and any Personal Data in it, will be publicly available on our website for all website users to see, for as long as the related blog continues to be published on our website. We do not use any Personal Data included in your comment to send you marketing materials or for any other purposes.

Cookies 

Our website may use a technology called a “cookie.” A cookie is a piece of information that our web server sends to your computer (to your browser file) when you access a website. Then, when you return to our site, it will detect whether you have one of our cookies on your computer. Our cookies help us analyze site usage more accurately.  

5. You Are Contacting Us via Email, Post or Telephone in Relation to a Matter Not Otherwise Covered by This Policy

Scope 

This section of the Privacy Notice sets out how we collect Personal Data when you correspond with us directly but in ways other than via our Surveys or Interviews, or through our website.

The Information We Collect 

We collect the Personal Data that you voluntarily submit to us in your email, telephone or postal correspondence, which in most instances will include your name and contact details. We may also request further Personal Data from you in order to respond to your correspondence. For example, if you contact us with a subject access request or other exercise of your data protection rights, we may request a form of ID from you in order to verify your identity.

How We Collect Information

How we collect your Personal Data depends on how you contacted us. If you have contacted us with a subject access request or other data protection request, we may create an electronic case file containing the details of your request. This normally includes your contact details and any other information you have given us. We’ll also store on this case file a copy of the information that falls within the scope of your request. We will not keep a copy of any ID you provide us with this case file.

The Way We Use the Information 

We use the Personal Data to respond to your query or request and our legal basis for using Your Data in this way is that it is necessary for the purposes of our legitimate interests of running our business. In some circumstances, it may also be necessary for us to process Your Data in order to comply with a legal obligation. For example, if you contact us with a subject access request or other data protection request, we may need to use Your Data in order to comply with our legal obligations under the GDPR.

The Way We Retain Data

We will retain Your Data for as long as is necessary to resolve your query or respond to your request. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We delete any ID we request in response to a data protection request as soon as we have verified your identity.

Who We Share Information With

When you submit a data privacy request or contact us in relation to this Privacy Notice, we may share certain Personal Data with our third party Data Protection Officer. We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law.

ADDITIONAL INFORMATION FOR EU RESIDENTS 

Your Rights in Relation to Your Data

Under the GDPR and/or Applicable Local Laws, you have the following rights in relation to how we process Your Data:

  • Right to request access – you may obtain confirmation from us as to whether or not Your Data is being processed and, where that is the case, to access Your Data

  • Right to rectification – you have the right to obtain rectification of inaccurate Personal Data we hold concerning you

  • Right to erasure – you have the right to obtain the erasure of Your Data without undue delay in certain circumstances

  • Right to restriction of processing or to object to processing – you may require us to restrict the processing we carry out on Your Data in certain circumstances or to object to us processing Your Data

  • Right to data portability – you have the right to receive Your Data in a structured, commonly used and machine-readable format

  • Right to withdraw consent – where you have provided your consent to us for processing Your Data, you have the right to withdraw this consent at any time. This can be done by emailing privacy@greenberginc.com at any time

  • Right to lodge a complaint – you may lodge a complaint with the supervisory authority in the EU Member State where you are resident or where you work. For further information on your rights, please see the relevant supervisory authority’s website.       

International Transfers

Greenberg is based in the United States and all of the data that we collect is processed in the United States. Some of our third party service providers are also based in the United States. Note that Greenberg is based in the United States and, by providing your Personal Data to Greenberg, you acknowledge that Your Data will be processed outside of the EEA.  

Greenberg participates in, and has certified its compliance with, the EU-U.S. Privacy Shield Framework (see the EU and Privacy Shield Statement below). It also complies with its obligations under the GDPR. Your Data is, therefore, protected to the same extent as it would be within the European Union.

All of our third party service providers who are based in the United States are also required to adhere to the EU-U.S. Privacy Shield Framework or to sign up to specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

EU and Privacy Shield Statement

In accordance with our commitment to protect personal privacy, Greenberg complies with the EU-U.S. and Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from European Union member countries and Switzerland. Greenberg has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. If there is any conflict between the terms in this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit www.privacyshield.gov.

Enforcement

Greenberg utilizes a self-assessment approach to ensure compliance with this Privacy Notice and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible, and in conformity with its principles. Greenberg also submits to being subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission, or any other U.S.-authorized statutory body with regard to our self-certification and implementation of these principles. 

Questions/Concerns

As part of our participation in Privacy Shield, if you have a question or dispute with us about our adherence to these principles, we will seek to resolve it through our internal complaint resolution process. You may contact us at privacy@greenberginc.com. You may also contact us by post at:

Greenberg, Inc. Compliance Team
1250 53rd Street, Suite 5
Emeryville, CA 94608
United States 

Privacy Shield organizations must respond within 45 days of receiving a complaint.

If you have not received a timely or satisfactory response to your question or complaint, please contact the Independent Recourse Mechanism, JAMS, at www.jamsadr.com/eu-us-privacy-shield.

You may file a claim using the link below, or by calling 800-352-5267:

EU Residents may have the option to invoke binding arbitration before the Privacy Shield Panel for the resolution of their complaint under certain limited conditions, through the Privacy Shield Arbitration Process. Individuals may invoke binding arbitration at no cost to the individual.

Policy Revisions

We may revise this Privacy Notice from time to time. The most current version of the policy will govern our processing of your Personal Data and will always be at greenberginc.com/privacy. If we make a change to this policy that, in our sole discretion, is material, we will notify you by placing a prominent notice on our site.


These Terms were last modified in January 2019