Privacy Policy

Who We Are and What We Do

Interviewing Service of America LLC, d/b/a icanmakeitbetter, ("us", "we" or "our") respects your privacy and is committed to protecting your personal information. We are an affiliate of Material Holdings, LLC ("Material") and perform market research and other services on behalf of our customers. Specifically, our platform enables Site Users and Business Subscribers to create, share and act upon ideas to drive innovation. By engaging with, accessing, and/or browsing our services, participating in any of our research studies (defined below), contacting us and communicating with us, or otherwise providing your data to us, such activities and the data processing that arises therefrom are guided by this Policy.

Definitions

A "Business Subscriber" is defined as a Site User that is a business or entity subscribing to our services in order to create a subdomain (e.g., [Business Subscriber].icanmakeitbetter.com) and manage and administer the platform for the use of their customers, employees or community. For clarity, references to Sites in this Policy also includes any Business Subscriber's subdomain. “Personal information” or “personal data” are terms we use interchangeably in this notice to refer to any information or combination of information that is reasonably capable of revealing your specific identity. Various jurisdictions define these terms slightly differently but generally align with this broad definition. The privacy laws of some jurisdictions (e.g. California, Virginia, and the European Union) define personally identifying information broadly to include the de- identified feedback you provide to us in Research Studies; even when it is impractical for us to reveal your identity with such information. Some jurisdictions (namely, the European Union and some states in the United States e.g. California, Utah, Virginia, Colorado, and Connecticut) also recognize a subset of personal information that is referred to as “sensitive personal information” or “special categories of personal data”. Examples of “sensitive personal information” include your ethnicity, religious beliefs, and sexual preferences. At any time, you may use our Your Data Your Rights privacy request portal (“Privacy Portal”) and/or our privacy request phoneline (see Your Rights As to Your Personal Data, below) to send us requests related to your privacy. When you make a privacy request, please be aware that it is often impossible to match your name, email, and other identifying information to records in our system because you may have entered into our system in a de-identified manner and we use best efforts to preserve your anonymity or pseudonymity in such instances. Nevertheless, we will use good faith efforts to find a record that matches you and, if found, we will process your request in accordance with applicable laws, industry customs, and our privacy policies. A “Site User” is defined as any entity accessing icanmakeitbetter.com or any of its related subdomains (e.g., “domain.icanmakeitbetter.com”) via mobile device, website or other platform administered by us (collectively, “Sites”) to create an account, post content, view and/or otherwise interact with the aforementioned Sites. Although there are myriad ways in which interested persons may participate in our services, for simplicity, references to the Sites includes, without limitation, the various surveys, forums, blogs, focus groups, and any other activities directly arising from your activities on the icanmakeitbetter service. Unless stated otherwise, the terms "you", "your", "user", or "users" -- for purposes of this Policy, means anyone accessing the Sties for any reason, including Site Users and Business Subscribers, you in your individual capacity and the company or other business entity(s) that you represent and on whose behalf you use the Sites under actual or apparent authority.

What We Do With Information We Collect From or About You

This "Policy" describes the information that we collect from any visitor to the Sites (e.g., www.businesssubscriberXYZ.icanmakeitbetter.com, www.brandxyz.icmib.com). Unless we distinguish otherwise, reference to "you" includes all visitors to our Sites. This Policy is incorporated by reference into the Terms and Conditions (which can be found at https://app.icanmakeitbetter.com/terms-and-conditions/) of the applicable Sites that you visit and/or interact with. The information that we collect is controlled by Interviewing Service of America, LLC, which is headquartered in the United States at 440 Park Ave So, 16th Fl, New York, New York 10016. We also act as a data processor, such as when we conduct surveys on behalf of and acting under the instructions of our Business Subscriber customers, who would be the data controller for such processing. In particular, if you are a Research Participant (defined below), we and/or our Business Subscriber (as appropriate) may collect a variety of feedback from you which may include “personal information” and “sensitive personal information”. Collection and processing of sensitive personal information is based on opt-in consent (in accordance with the GDPR and the Data Privacy Framework Principle of "Choice") and/or alternative legal bases available to us under the circumstances. Research Study participation is voluntary, and participants have the opportunity to “opt out” of the research after agreeing to participate. If you cannot find the instructions on how to “opt- out” of a Research Study, please contact us in the manner specified in the Your Rights As to Your Personal Data section (below).

How Our Sites Work

Business Subscribers will engage the Sites for a variety of products and services, including to create surveys, forums, communities, and other research activities. The Site commissioned by the Business Subscriber will send an invitation to you (to participate in one or more research activities. The invitation will be sent to the contact information that you or the Site User provides to us). Invitations sent are intended to.

Information We Collect

We collect information from a variety of sources, including information we collect from third parties and evidence collected from you directly when you create an account, visit our Website, use our services, register to make comments on the Sites, or request information from us.

• INFORMATION WE COLLECT DIRECTLY FROM YOU

Business Subscribers: We collect contact information from potential customers and our Business Subscribers in order to administer our relationship with our customers and to respond to inquiries. This information includes name, business email address, business phone number, and company name. We also collect information about how Business Subscribers navigate and use the Site(s) (as described below).

California-Resident Service Provider Data

If you are (or work for) a Business Subscriber (or a client or vendor) engaged with us, we likely have collected various contact, business, and in some cases financial information about you in the course of procuring our Services. In those cases, our legal basis for the collection and processing of the information includes our legitimate interest to perform our actual or expected obligations with you or the company you represent. California residents should further consult our California-Resident Privacy Notice for more information about the information we collect in this context. We may collect certain information regarding visitors to our Services, including IP address, device and browser type, date and time of visit, name of the visitor’s Internet service provider, state or country from which the Services were accessed, web pages from which the visitors linked to the Services, and behavior while on the Services (e.g., which links were clicked on). We may do so using cookies, which are small files placed on your internet browser when you visit our Services, to offer you a more tailored experience in the future by, for example, understanding and remembering your particular browsing preferences. Occasionally, cookies, pixels, or web beacons may be placed on our Services by service providers or partners; we do not permit data that reveals your identity to be collected or accessed by these cookies, pixels, or web beacons. If you prefer not to receive cookies from our Services you can disable their use in your web browser settings. By doing so you may reduce the functionality of the web pages you view. Currently, our systems do not respond to browser do-not-track signals, and we do not treat such do-not-track signals as “do not sell” signals under the CCPA (as defined below).

Survey Participants: You are required to create an account with us if you would like to participate in any research activities on the Sites. To create an account, we require you to provide us with your email address and to create a user name and password. You may have an opportunity to create a user profile; the items requested in the user profile will vary based on the Business Subscriber, but may include your name, contact information, gender and interests. If you do not create a user profile on a research project that requires it, you will be ineligible to participate in such research. You also may have the option to log onto our Website with third-party login authenticators such as social networks credentials e.g. Facebook, Twitter, Google+, and LinkedIn. The third-party authenticators determine what information will be collected from you during the log-in process. Depending upon the particular social networking site, we may request certain permissions from you. For example, if you log in through Facebook Connect, we request your permission to: access your Facebook profile basic information, including, your name, profile picture, gender, list of friends and user ids, email address, date of birth, and any other information you have set to public or to be shared on your account; send email directly to you; post to your wall; and access your data at any time even if you are not using Facebook. Please note, if you log-in this way, you allow us to have access to this information even if you have chosen not to make that information public on the respective social network. For information about how a particular social networking site may disclose your information, including any information you make public, please consult the site’s Privacy Policy. We have no control over how these sites use or disclose the personal information you provide to them. We store the information that we receive from them along with other information that we collect from you or receive about you.

• INFORMATION WE COLLECT FROM THIRD PARTIES

We may collect information about you from third parties, such as a Business Subscriber that previously collected your information, or from your social media accounts when you choose to login to one of our Websites using your social media account as described above,. The information we collect from third parties includes your name and email address, so that we may contact you and ask you to participate in our research activities. In some research activities, we may collect publicly available information, including comments made in connection with product reviews or on social media which may, from time to time, include a “handle” or “username” you used to identify yourself on those platforms. We use reasonable commercial efforts to avoid collecting identifying information. Our legal basis for collecting and processing such publicly available information is our legitimate interest to perform our obligations under our contract with the client commissioning the research study in question.

• INFORMATION WE COLLECT WHEN YOU VISIT OUR WEBSITE

When you interact with our Sites, we strive to make your experience meaningful and easy. We may use or engage others to use cookies, clear gifs, or other tracking technologies to track user engagement and to collect Sites data. Specifically, when you visit our Sites and use our services, we may collect the following information: IP addresses, browser type, operating system, date and time of visit, time spent on and/or logged onto the Site, browser referral header or other mechanism by which you came to our Sites, and links clicked on in our Sites. We may combine this information with other personal information that you provide to us by using the Sites. From time to time, we engage the services of technology infrastructure vendors, such as “chat” service providers that have the ability to conduct text-based and audio/video-based communication, in connection with our Sites to improve our customer experience, and these vendors collect information from Sites visitors for the limited purposes for which we have engaged them.

Cookies

When you access our Sites, we use cookies. Cookies are alphanumeric identifiers that we (and other third party Sites operators) transfer to your computer’s hard-drive through your web browser for record- keeping purposes. There are two types of cookies; session-based and persistent-based cookies. We also may permit certain third party cookies to be placed on our Sites. Some of the cookies we use are essential for parts of our Sites to operate and are required to remain active. You may delete and block all other cookies from our Sites (most web browsers allow some control of most cookies through the browser settings), but doing so may prevent features and access of all or parts of our Sites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies we deem necessary for the expected operation of our services as soon as you visit our Sites. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. For detailed information about cookies and how they are used on our website, see our Cookie Policy.

• SESSION COOKIES

Session cookies exist only during then-current online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you while you are logged into the Sites. This allows us to process your online transactions and requests, and to verify your identity after you have logged in, as you move through our Sites.

• PERSISTENT COOKIES

Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We may use persistent cookies which may be combined with other user information.

• THIRD-PARTY COOKIES

We also may engage third parties, including, without limitation, Google Analytics, to track and analyze non-personally identifiable Sites data. We use the data collected by such third parties to help us administer and improve the quality of the Sites and Services and to analyze usage. We do not have access to or control over these third-party cookies, nor does this Privacy Policy cover such third parties’ use of data collected by them.

• DISABLING COOKIES AND DO NOT TRACK

Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The settings on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Sites visitors who disable their web browser’s ability to accept cookies will be able to browse the Sites; however, you must enable cookies to use most of our Services as they were intended. Currently, our systems do not respond to browser do-not-track signals and do not treat such do-not-track signals as “do not sell” signals under CCPA (as defined below).

• PIXELS, WEB BEACONS

We (or the third parties we engage to track and analyze Sites data) may employ Pixels and Web Beacons to help us better manage content on the Sites. These are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on your computer's hard drive, pixels are embedded invisibly on Web pages. We and our third-party service providers also use such technologies for email communication to help us track email campaign efficacy.

• IP ADDRESSES

An IP address is a computer's numeric address, by which it can be located within a network. We record your IP address when you visit or use services or features on the Sites. We use your IP address for the purposes described in this privacy policy, to help diagnose problems with our server, and to administer the Sites. We may also use your IP address to identify you when we feel it is necessary to enforce compliance with this Policy, the Terms and Conditions and/or Cookie Policy, or to protect the Sites, systems, information, employees, service providers, business partners, users, customers and others.

Using Your Information

Subject to the limitation on how we use your survey responses discussed in the section entitled “Additional Information about Your Participation,” we use the information that we collect from you through your participation in our Services, and on our Sites for the following purposes:

We may combine all of the information that you submit through our Sites, including, for example, your profile information along with your responses to our surveys. We also will use your information to provide Services to our Business Subscribers. This may include compiling and reviewing your research responses. We describe what information we share with Business Subscribers below in the “Sharing Your Information” Section. As described above, we act as a data processor on behalf of our Business Subscribers. When we act as a data processor, such as when we conduct a survey on behalf of a Business Subscriber, we act in accordance with our Business Subscriber’s instructions and such processing will be governed by the Business Subscriber’s privacy policy, which supersedes this Policy .

The Legal Basis for Using Your Information

We collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This may be because:

If you would like to find out more about the legal basis for which we process personal information, please complete your request on our privacy request portal: www.materialplus.io/yourdatayourrights

Sharing Your Information

We may share information about you as described herein. We do not sell, rent, or give away your personal data to any third party for the purpose of directly marketing any products or services to you; and we have not done so in the preceding 12 months. However, certain laws (such as the California Consumer Privacy Act (the “CCPA”)), define the terms “sell” and “sale” very broadly. Under the CCPA, some of our research-related activities might fall within the definition of a “sale” of personal information in limited circumstances. Additionally, we do not discriminate financially between those who elect to supply their personal data to us and those who elect not to do so. Notwithstanding the foregoing, if a survey or other research study leads to the payment of a financial incentive, entry in a sweepstakes or other valuable consideration, and such study involves the collection of data but you decide not to provide such data, you would not be able to proceed to participate in the study. For example, an attempt to collect your personal data may be made to validate your participation in a research study and/or to provide you with an incentive. If you decline to provide your contact information, we will not be able to validate your participation nor provide you with the applicable incentive. When we collect your contact information for incentivization, we use good faith measures to avoid associating it with your research-related feedback. Our legal basis for the collection and processing of Research Participant-supplied identifying data is consent. Consent can be withdrawn at any time. We contractually require third parties to whom we transfer personal information to provide the same level of protections as set forth in this policy.

• Site Users

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. If you choose to participate in our Services, we may share the information we collect about you and your interactions with our Sites with the Business Subscriber for whom we are acting as a data processor. This will include your responses to the research activities, as well as your contact information and profile information, unless you participated in our Surveys and Services on an anonymous basis. The Business Subscriber may use your information, at a minimum, for purposes consistent with this Policy, which may include for market research, for sales and marketing, and for other purposes described herein. The Business Subscriber, however, also may maintain its own privacy policy; if the Business Subscriber invited you to participate in its unique Site, then the information that you submit also may be subject to the privacy policy of the Business Subscriber. The Business Subscribers may contact you directly if you respond to or participate in research activities unless your participation is on an anonymous basis.

• Partners and Subsidiaries/Vendor Companies

We may disclose your personal information to our holding company, subsidiaries, affiliates. We may also disclose your personal information to third parties whom we instruct to provide services on our behalf, including, but not limited to, support services, website services, delivering promotional materials, and other promotions, and answering customer questions about our products and services. We will only provide those third parties with the personal information that they need to deliver the services to us and/or on our behalf. We may share your information with our partners and subsidiaries as well as hire vendor companies to provide limited services on our behalf, such as payment processing, sending postal and electronic mail, providing technical support, and to assist us in providing the products and services that you request from us. We only provide those service providers with the information necessary to perform the requested service. If you choose to participate in our Services, we may share your contact information and non- personally identifiable information (such as information obtained through cookies) with our partners and subsidiaries. We also may combine all or any portion of the information we collect or acquire. Our partners and subsidiaries will use your information consistent with the purposes described in this Policy.

• Other Visitors To Our Site

Depending upon the particular Site Activity, your responses also may be viewable by any other visitor to that website. For example, if you participate in a blog or forum, your responses will be viewable by other visitors to that website.

• Sale/Transfer of Business

We reserve the right to disclose your information if we license, sell, or otherwise transfer our technology or business, or a portion thereof, to any third party in connection with a change in control, including, without limitation, by way of a purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving our parent, subsidiary or affiliate.

• To Protect Ourselves/For Legal Purposes

We also may disclose your personal information to protect our rights and property, to prevent against fraud and abuse, and to protect other users of our services. We also may disclose your information as permitted or required by law, for example, in response to court orders, subpoenas, or other requests from government agencies. In accordance with our legal obligations, we may also transfer, subject to a lawful request, personal information to public authorities for law enforcement or national security purposes.

SUMMARY RELATING TO CATEGORIES OF PERSONAL INFORMATION THAT WE COLLECT

Category of consumer personal information collected (non-HR) Source from which collected Purpose for which collected Categories of third parties with whom shared
Username, name and contact information - research participants Study participant - sometimes, client commissioning study Inviting participation in study;; administering studies; fulfilling participation incentive Study-related vendors; technology infrastructure vendors
Demographic details - research participants Study participant; sometimes social media or client commissioning study Administering study Study-related vendors; technology infrastructure vendors
Content shared by participant as part of study (e.g., video, audio, photo) Study participant Administering study Client commissioning research study; study-related vendors; technology infrastructure vendors
Name and contact information - website visitor Supplied by person himself/herself Marketing of Sites' own services Technology infrastructure vendors
Name and contact information - client officer Supplied by person himself/herself Administration of business Technology infrastructure vendors
Systems details - visitors to Websites (IP/device ID, browser settings, similar) The computer or device of the person himself/herself Internal analytics improvement of Website experience Technology infrastructure vendors

Additional Information About Your Participation

We administer the Sites on behalf of our Business Subscribers, where we act as our Business Subscribers’ data processor. We may create the Sites on behalf of the Business Subscriber, or the Business Subscriber will create the Site(s) itself, and provide to us to administer. Regardless of which entity authors, a particular Site(s), we will host the Site on our servers, located in the United States, and collect the responses that you submit. In some circumstances, we also will analyze the data and provide that analysis to the Business Subscriber, and in other situations, we share the survey responses in their entirety to the Business Subscriber. We do not share your individual survey responses with any person or entity other than the company (or its affiliated entity) that engaged us to create the survey. We may, however, provide your contact information and aggregate information to our partners and subsidiaries, but we will not provide your actual survey responses to our partners or subsidiaries. Subject to the obligations found herein, we are not responsible for any information that you submit through this website. If a Business Subscriber invited you to participate in a research study, such invitation (and your participation related thereto) are subject to the Business Subscriber’s privacy policy. Whether your research participation responses to a particular Survey or Forum is anonymous depends upon the Business Subscriber’s choice. Some research studies will permit you to respond anonymously, whereas others will require your name. (or possibly a pseudonymous identifier) and other contact information. We will notify you on the applicable Site if you are required to provide personal information in order to participate in a research activity. Providing personal information is your choice and you can end your participation at any time and withdraw your consent to the use of any personal information you provided using the privacy portal referenced in this Policy.

Third Party Sites

Please note that the Sites may, from time to time, contain links to third-party websites, applications and other platforms and services that are not controlled or operated by us. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for such policies nor can we control the processing of your information on their properties. We advise all Site Users to review their policies and related terms and conditions before you disclose any personal information when visiting such third party websites.

Security

We maintain physical, electronic, and procedural security measures to help safeguard client and personal data which are consistent with industry standards and practice and in compliance with applicable law (our “Safeguards”). Notwithstanding the category of individuals about whom personal data is collected, our Safeguarding is designed to use commercial best efforts to protect the data we process from loss, misuse, unauthorized access, disclosure, alteration, and destruction. While the specific Safeguards we use vary depending on the circumstance of the Processing activities, they include, (1) a cybersecurity program and data privacy program, (2) data breach incident management procedures, (3) periodic self-assessments and third-party assessments, and (4) penetration tests. The technical and organizational safeguards we employ meet the applicable standards of industry practice that are relevant to our business activities and the volume and sensitivity of the data we process. Third parties that provide us with support or services and that may also receive personal data are required by us to maintain safeguarding measures similar to ours with respect to such information. We cannot protect, nor does this Policy apply to, any information that you transmit to other users.

Children/Minors

You must be at least 18 years of age to use this Website. The services available on this Website are not intended for persons under 18, including, in particular, children under 13, and we do not knowingly collect nor sell the personal information of persons under 18 years of age. User Generated Content Portions of our Website permit users to engage in publicly viewable research activities and are therefore not confidential. We are not responsible for the privacy of any information that you choose to submit through a public forum, such as a blog, or for the accuracy of any information contained in those postings. Any information that you disclose in such publicly viewable research activities becomes public information. Notwithstanding our reasonable commercial efforts, we cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy. Please refer to our Terms and Conditions https://app.icanmakeitbetter.com/terms-and-conditions for additional information relating to user submissions that might apply to you.

Retention of Your Personal Information

The personal information that you provide will be retained for as long as necessary to provide our services to you, to fulfil the purposes described in this Policy and/or our business purposes, or as required by law, regulation, or internal policy.

Your Privacy Rights Under Applicable Laws

You may have certain privacy rights under the laws of your jurisdiction (e.g. GDPR, CCPA, and other applicable laws) to know certain details regarding our data handling practices generally. This information is described above and elsewhere in this Privacy Policy. If such laws apply to you, you may have the right (subject to applicable limitations and exceptions) to request the following: that we provide access to any personal data we hold about you; that we update any of your personal data which is out of date or incorrect; where our basis for processing your personal data is consent, that your consent to further processing be withdrawn; where we received your personal data from a third party; inquire where the data originated; that we delete any personal data which we are holding about you; that we restrict the way that we process your personal data (including that we no longer “sell” your personal data); or that we not “share” your personal data to third parties for cross-context behavioral advertising; that we prevent the processing of your personal data for direct-marketing purposes; that we provide or not provide, your personal data to a third party; that we provide you with a copy of any personal data which we hold about you; that we consider any valid objections which you have to our use of your personal data; and that you not be discriminated against for exercising any of your privacy rights.; that you initiate a private cause of action for data breaches; and that we limit the use and disclosure of sensitive personal information. Under applicable law, certain personal data may be exempt from some of these requests. Also, if you wish to request that we restrict processing of your personal data in a particular way that would be operationally impractical for us to execute, we reserve the right to instead remove, delete or otherwise render your personal information non-identifiable from our systems in lieu of the operationally impractical request. In the case of Research Participants, an operationally impractical request may result in disqualification from participating in a Research Study, permanent revocation from membership in Our Panel, and/or forfeiture of incentives, rewards, and prizes. If the GDPR applies to you, you also have the right to inform your local supervisory authority of any concerns related to your personal data. If you would like further information about these rights or would like to exercise any of them, including to opt out of the “sale” of your information as defined in the CCPA, please leave us a voice message by calling (833) 324-5165 (*NO PIN), or submit your question or request at www.materialplus.io/yourdatayourrights. To exercise privacy rights in your capacity as our employee, job applicant, independent contractor, or the personnel of our clients and vendors, please contact privacyrequests@materialplus.io. Your right to access your personal data may be restricted in exceptional circumstances, 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 when 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. By law, as well as for your protection, if you use one of the methods in the previous paragraph to make a privacy request we may verify your identity before processing your request. If we are not able to verify your identity, understand your request, or if your request is not privacy- related, we will not process your request. To verify your identity, we will generally request, certain identifying information, combined with non-personally identifiable information (e.g., information relating to your last interaction with us) and we endeavor to match at least two pieces of this information with information in our possession in order to verify that you are authorized to make your privacy request. In addition, as to those rights permitted by law to be exercisable by an authorized agent on your behalf, in addition to verifying your identity as described above, we require the agent to also supply written authorization from you to act on your behalf, except where restricted by law. Note, some of these rights may not be applicable to information which we might collect or process from or about you in your capacity as our employee, job applicant, or independent contractor; there are other laws applicable to those relationships which are not addressed in this Privacy Policy. If you have any questions, please contact us by mail "c/o Legal Department" at the address provided in this section above.

Compliance and Enforcement; Data Privacy Framework and Cross Border Transfers

We comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. We have certified to the U.S. Department of Commerce that we adhere to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. We have certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/. We and certain other affiliates of Material, generally maintain servers and systems in the United States hosted by third party service providers. We also may subcontract the processing of your data to, or otherwise share your data with, other third parties in the United States or countries other than your country of residence. As a result, where the personal information that we collect through or in connection with the Website is transferred to and processed in the United States or anywhere else outside the European Economic Area (EEA) for the purposes described above, we will take steps to ensure that the information receives the same level of protection as if it remained within the EEA, including entering into data transfer agreements, using the EU Commission’s approved Standard Contractual Clauses, and/or adherence to the Data Privacy Framework Principles (described in the EU-US and Swiss-US Data Privacy Frameworks). Material is subject to the investigatory and enforcement authority of the FTC. Also, as members of the Insights Association and ESOMAR, we strive to model our policies according to guidelines promulgated by those organizations. Our Privacy Officer is available if you have questions about our Privacy Policy, or for processing a complaint. Please refer to the contact information described above under the heading “Your Rights As to Your Personal Data”. In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, We are committed to resolving DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Us at: http://www.materialplus.io/yourdatayourrights. In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, We are also committed to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF in the context of the employment relationship. In compliance with the EU-US Data Privacy Framework and Swiss-US Data Privacy Framework Principles, Material commits to resolve complaints about your privacy and our collection or use of your personal data. European Union, British, and Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Material as described above under the heading “Your Rights As to Your Personal Data.” Material takes responsibility for cross-border onward transfers to third parties made in a manner that is inconsistent with the Data Privacy Framework Principles referenced herein. In compliance with the EU-US Data Privacy Framework Principles, we are committed to resolving complaints about your privacy and our collection or use of your personal information. European Union and Swiss individuals with inquiries or complaints regarding this privacy policy should first contact us through our privacy request portal at: www.materialplus.io/yourdatayourrights In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Material commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to INSIGHTS ASSOCIATION DATA PRIVACY FRAMEWORK PROGRAM, an alternative dispute resolution provider based in the United States. Under certain conditions, you may have the right to invoke binding arbitration. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.insightsassociation.org/Resources/Data-Privacy-Framework for more information or to file a complaint. The services of INSIGHTS ASSOCIATION DATA PRIVACY FRAMEWORK PROGRAM are provided at no cost to you. Finally, if required or permitted by law, you may also make a complaint to the data protection authority in the EU country or Switzerland where we may have operations or where we process personal data that relates to offering goods or services to you in the EU or Switzerland. EU, British, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you. Upon such request, subject to the limitations specified in this Policy, we will provide you with access to the personal information that we hold about you. An individual who seeks access, correction, amendment, or deletion of their personal data, should direct their query to our privacy request portal at www.materialplus.io/yourdatayourrights. We remain responsible and liable under the Data Privacy Framework Principles if third-party agents that we engage to process the personal data on our behalf do so in a manner inconsistent with the Principles, unless we provide evidence that we are not responsible for the event giving rise to the damage.

Additional Privacy Notices That May be Applicable To You

California-Resident Business Service Providers. Material’s California-resident personnel (which includes, Material’s employees and independent contractors), and also the California-resident personnel of Material’s clients, vendors, and similar service providers should refer to Material’s California-Resident Privacy Notice for additional privacy disclosures. In the event of a conflict between the California-Resident Privacy Notice terms and the terms herein, the former terms shall prevail for California-resident personnel.

Changes

We may periodically update this policy. We will notify you about significant changes in the way we treat personal information by sending a notice to the email address specified in your primary Site User account or by placing a prominent notice on this Website or blog.

Last Update: 1/16/2024, 1:43:06 PM