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PRIVACY POLICY - Effective May 24th 2018

Acumen Panel is the Behaviour & Attitudes online consumer panel. Behaviour & Attitudes are an independent market research company with a registered address of Milltown House, Milltown Dublin 6 (referred to as "Acumen Panel", “we”, “our” or “us”).

The primary purpose of why we collect information is in order to conduct  market research; gathering Acumen Panel members' views, experience and opinions and thereby providing insights on a wide variety of different topics. 

When you join Acumen Panel we enter into a contract with you. We never use your information to try to sell you anything or sell your details to any organisation which might want to sell you anything or sell your information for marketing purposes.

We are committed to protecting your privacy. At all times we aim to respect any personal information you share with us, and keep it safe and secure. 

This privacy notice sets out how we process data, information on your rights and options regarding the ways in which your personal information is used and collected. We hope that we have made it is a simple to read as possible but should you have any queries please do email us at Conor@acumenpanel.ie DPO queries to dpo@banda.ie or write to us for the attention of the Data Protection Officer, Behaviour & Attitudes, Milltown House, Mount Saint Annes, Milltown, Dublin 6.

What type of information do we collect?

Acumen Panel collects data when you register to be become a member of the Panel, when you participate in surveys or other research opportunities (such as discussion forums or product tests) and also when you visit the Acumen websites. This data is collected in both an active and passive way

Registration

Choosing to join Acumen Panel is entirely voluntary and up to you. When you register as an Acumen Panel member you actively provide information as part of your membership including your name, username email address, password, gender, age, county etc.This information (or as updated by you at a later stage) is required to create your Acumen Panel account, issue rewards and is also used to send survey invitations relevant to you.

Active Data Collection

Active data collection is where for example during a survey or profile update you provide an answer, click on a statement or write a response to question or form or in corresponding with us. It includes information you provide such as when you register, enter competitions, or participate in discussion forums.

Passive Data Collection

Passive data collection occurs automatically when you interact with a survey, the Acumen Panel website or Acumen Panel registration. This can include the time of the interaction, the IP address, internet browser and information about the device being used. This information is used to properly display surveys or information, as part of survey administration or in the payment of incentive points or rewards.

Website

When you visit our website, we may automatically collect the following types of information:

Technical information, including the internet protocol (IP) address used to connect your device to the internet, browser type and version, time zone setting, browser plug-in types and versions and operating systems and platforms.

Information about your visit to the website, including the uniform resource locator (URL) clickstream to, through and from the website (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, referral sources, page interaction information (such as scrolling and clicks) and methods used to browse away from the page.

We may also use “cookies” to improve your experience as you use our website. Cookies are small data files that allow a website to collect and store a range of data on your desktop computer, laptop or mobile device.  We may use cookies and similar technologies, such as tags (“cookies”) to help us to provide features and functionality on our website. We currently use cookies that we set (called ‘first party cookies’) and we may set third party cookies (which are not set by us, but by other websites with our permission - Google Analytics. Third party cookies such as Google Analytics are currenly disabled from this site) We will ask you permission to set such third party cookies.

Acumen Panel Surveys

Participation in any Acumen Panel survey is always voluntary, so you can choose not to take part in a survey or to opt out at any time by closing your browser and not returning to the survey. Only fully completed survey responses will be included. Personal identifiable data will not be linked to any results or shared with our clients. Acumen Panel survey results are only presented in anonymous form.

Survey and participation infomation is also used for internal analysis and the overall administration of the Panel, membership and rewards. 

Sensitive Data
The EU General Data Protection Regulation recognizes that certain categories of personal information as sensitive and therefore require more protection, for example information about your health, ethnicity and religious beliefs, trade union membership, sex life or orientation. In instances where we are conducting research for example involving questions relating to sensitive data such as this detailed in the Regulation we will always ask for your informed explicit consent.

Acumen Panel Profiles
In order to invite members to appropriate surveys, we use profile information such as that requested during Acumen Panel registration or during surveys which are identified as profile surveys. Limited demographic information including county, urban rural is also updated, where applicable during Acumen Panel surveys, in order to keep this information accurate. 

Taking part in additional profile surveys is entirely voluntary - members can chose to take part or not to answer any question. This will not prevent members from receiving invitations but may impact the number of surveys they receive that are relevant to them. Processing profile information may use automated means, such as randomly selecting some of all the Acumen Panel members who fit the basic criteria for a research study to send invitation.

How long will we keep the information provided?
We will keep the profile information you provided for as long as you remain an Acumen Panel member. You can of course leave the Panel at any time you wish. 

Where we obtain personal identifiable data we store it in a safe and secure manner with limited access, in compliance with our ISO 27001 and all relevant Data Protection legislation. Any personal identifiable data linked to market research surveys is stored for no more than 12 months after which it is securely destroyed – unless explicit informed consent is given by individuals to store it for longer.

How do we use personal information? 
We will only use personal data when the law allows us to. When you join Acumen Panel, we enter into a contract with you, subject to this Privacy Policy as well as our Terms and Conditions. In order to fulfill this we send you survey invitations, collect, process requested during registration or which you may subsequently add to your profile or that we collect in accordance with this Privacy Policy.

The General Data Regulation requires us to rely on one or more lawful bases to use your personal information. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Most commonly, we will use your personal data in the following circumstances:

Where necessary for the performance of a contract to which you are a party as an Acumen Panel Member, or to take steps  prior to entering a contract.  

Where you have provided your consent for us to use your personal information in a certain way (for example, where you have given explicit informed consent to to the processing of sensitive data as part of a survey).

Where necessary so that we can comply with a legal obligation to which we are subject

Where there is a legitimate interest in us doing so (such in administering our business or protecting the website or data environment (including business performance analysis, testing, system maintenance, support, reporting and hosting of data) 

The GDPR allows us to collect and process your personal information if it is reasonably necessary to achieve our or others’ legitimate interests (as long as that processing is fair, balanced and does not unduly impact your rights as an individual).

In broad terms, our “legitimate interests” means the interests of running of Acumen Panel as a commercial entity and ensuring the best possible user experience.

We will not use your personal information for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law). Please contact us by emailing dpo@banda.ie if you need details about the specific legal ground we are relying on to process your personal data.

Incentives and Data Sharing 
By making a request to redeem incentive points that have been accumulated on Acumen Panel, we will share limited personal data with our rewards partner Allgo.ie (66 Camden Street Lower, Dublin 2, Ireland). The data shared is limited to the extent needed to send you an Allgifts voucher via email.  

How you can edit and delete your information
You can view your basic membership data the the members area after you sign in to the Acumen Panel website. 
Click the member area tab and to correct any errors click on edit profile. 

If you have any queries in this regard please do not hesitate to contact Acumen Panel at info@acumenpanel.ie or conor@acumenpanel.ie and we can edit or delete the information for you.

If you no longer wish to be a member of Acumen Panel, you can close your account by emailing stop to conor@acumenpanel at the bottom of any email invitation sent to you, by emailing conor@acumenpanel.ie or info@acumenpanel.ie. Your Acumen Panel account will be deleted within 2 working days. When you unsubcribe you will lose any un-redeemed points you may have earned during your membership period. Limited personal data will only be retained in so far as is required to meet the requirements of Data Protection regulation.


Transferring personal data outside the EEA 

As we are an independent market research compnany based in Dublin we would normally only transfer your personal information within the European Economic Area (“EEA”), where countries have the same level of data protection law as under the GDPR.

Please note that some countries outside of the EEA have a lower standard of protection for personal information, including lower security requirements and fewer rights for individuals. 

In the event that we were to use agencies and or suppliers to process personal information on our behalf, it is possible that personal information you could be transferred to and stored in a location outside the EEA, for example the United States. In which case we would ensure on safeguards when transferring data to companies based in the US that those companies are Privacy Shield certified or to a standard as required by law. The US Privacy Shield is a program agreed between the EU and US which aims to protect the personal data of anyone in the EU when it is transferred to the US by placing data protection obligations on US companies that receive personal data from the EU.  

In the event that your personal information is transferred, stored and/or otherwise processed outside the EEA in a country that does not offer an equivalent standard of protection to the EEA, we will take all reasonable steps necessary to ensure that the any recipient implements appropriate safeguards such as entering into Standard Contractual Clauses as set out by the European Commission designed to protect your personal information and to ensure that your personal information is treated securely and in accordance with our privacy policy.

In the event Acumen Online or its affiliates experience a merger, acquisition, sale or other transaction pursuant to which this website is acquired by a third party or an affiliate of Acumen Panel, Acumen Panel in so far as allowed by law, may disclose your personal information to the third party or affiliate both before and after the transaction, for the sole purpose of facilitating and effecting that transaction. In the event a transaction is consummated, you will be notified of the transaction via e-mail and through a notice on our website, and Acumen Panel custody of your personal information will be transferred subject to all the terms and restrictions in the privacy policy. In the event the transaction is not consummated, Acumen Panel will require the third party or affiliate not to use or disclose your personal information in any manner whatsoever and to completely erase same.

Use of Cookies

This section sets out how we collect and analyse information about Acumen Panel Members’ online history, and all of the actions we take to protect the privacy and the security of that website usage data we collect.

All the statistical information regarding online history that is collected by Acumen cookies during the time spent by our panelists on our site is considered confidential. To protect this information from loss, misuse and unauthorized access, disclosure, alteration and destruction, Acumen Online has implemented industry standard security measures including firewalls and security analyzers using SSL encryption to protect the transmission of data. Access to the protected data is limited to a select few authorized Users.

Performance cookies are used to collect statistical information about visitors of the website and the pages they view. These cookies don’t collect information that identifies a visitor to the Acumen Panel website. All information these cookies collect is aggregated and used anonymously. Google Analytics and such services are currently disabled from setting cookies on the Acumen Panel website. We may use these cookies to understand how users engage with our content, which helps us to improve our website such as Google Analytics. Google Analytics is a web analytics service provided by Google to help us see how our website is used. In using Google Analytics information about your use of our website, including your IP address, may be transmitted to Google and stored on servers in the United States. Data collected by Google Analytics is used to analyse how frequently the same people revisit the Acumen website, how the website is found (from advertising or referring websites), and which pages are most frequently viewed. This information is combined with data from thousands of other users to create an overall picture of website use, and is not linked to any other information we store about you. We will ask for your permission for setting such cookies. For more information on how to manage cookies, including opt-out of performance cookies please visit: http://www.aboutcookies.org/Default.aspx?page=1

Some cookies that have been set on our websites are not related to Acumen or our partners. If you were to visit a page with content embedded from, for example, YouTube or Facebook, these service providers may set their own cookies on your web browser. We do not control the use of these cookies and cannot access them due to the way that cookies work, as cookies can only be accessed by the party who originally set them. You should check the third party websites for more information about these cookies.

Contact and Data Access requests

If you have any queries in relation to your data or if you would like to make a data access request please email us at dpo@banda.ie or write to us for the attention of the Data Protection Officer, Behaviour & Attitudes, Milltown House, Mount Saint Annes, Milltown, Dublin 6.

A guide to your rights is available on the website of the Data Protection Commissioner www.dataprotection.ie You are also further entitled to make a complaint to the Data Protection Commissioner –  

Please note for any Data Access requests please complete our Data Access request form which you can download from the B&;A website here . Data Access Request

We will require the following information so that we process your request:

1. Proof of identity  

2. The type of research you participated in 

- Online survey

Please specify Acumen Panel in your data access request. 

Jurisdiction

This Privacy Policy constitutes the entire agreement between you and Acumen Panel regarding privacy and data protection.

This Privacy Policy shall be governed by and construed in accordance with Irish Law. All disputes with regard to or arising in connection with the privacy policy shall solely be submitted to a competent judge in Ireland.