Privacy Policy

Effective Date: January 1, 2010

Last Revised: May 24, 2018

Sentient Services, LP, d/b/a icanmakeitbetter (“icanmakeitbetter”, “we” or “our”) respects your privacy and is committed to protecting your personal information. We are an affiliate of Lieberman Research Worldwide, LLC (“Lieberman Research Worldwide” or “LRW”) 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 and make everything, and every day better. A “Site User” is defined as any entity accessing icanmakeitbetter.com, any icanmakeitbetter.com subdomain (e.g., “domain.icanmakeitbetter.com”) or survey or forum (via mobile, website or other form administered by icanmakeitbetter) to create an account, post content, view or interact with the aforementioned icanmakeitbetter domains, subdomains, surveys and properties. A “Business Subscriber” is defined as a Site User that is a business or entity subscribing to Company 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 this Website in these Terms and Conditions also include any Business Subscriber’s subdomain. Unless we distinguish otherwise, the terms “you”, “your”, “user”, or “users” for purposes of these Terms and Conditions, mean anyone accessing the Website for any reason, including Site Users and Business Subscribers, you in your individual capacity, and the company or other business entity that you represent and on whose behalf you use the Website under actual or apparent authority.

On our Website, we also may provide opportunities for interested persons to share ideas with us, for, example, through a blog. Although there are myriad ways in which interested persons may participate in our Website, for simplicity, we refer to the various surveys, forums, blogs, focus groups, and any other activity on our website as collectively “Surveys and Forums”.

In this (“Policy”), we describe the information that we collect from any visitor to our website,www.icanmakeitbetter.com and www.icmib.com, as well to our websites operated by us, e.g., www.businesssubcriberXYZ.icanmakeitbetter.com, www.brandXYZ.icmib.com (where the icanmakeitbetter name will vary based upon our customer and the domain you are using - collectively these entities are referred to as “Website” in this Privacy Policy). Unless we distinguish otherwise, references to “you” include all visitors to our Website. This Policy is incorporated by reference into our Terms and Conditions of our Website, available at https://app.icanmakeitbetter.com/terms-and-conditions/.

The information that we collect is controlled by Sentient Services, LP, which is headquartered in the United States at 15400 Sherman Way, Ste. 400, Van Nuys, CA 91406. 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.

How icanmakeitbetter.com Works

Business Subscribers will engage icanmakeitbetter for a variety of products and services, including to create Surveys and Forums.

icanmakeitbetter will send an invitation to you (using contact information that the Site User provides to us) to participate in the Surveys and Forums, which may include, for example, responding to a survey, posting a comment, or sharing an idea.

Information We Collect

We collect information from a variety of sources, including information we collect from you directly when you create an account, visit our Website, use our services, register to make comments on Forums or blogs, 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 Subscriber users navigate and use the Website (as described below).

Survey Participants: You are required to create an account with us if you would like to participate in any Surveys and Forums. To create an account, we require you to provide us with your email address and to create a user name and password. You will have the opportunity—but are not required—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.

You also may have the option to log onto our Website through third-party social networks such as Facebook, Twitter, Google+, and LinkedIn, among others, which may change from time to time. The third- party social networking sites 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 allow us to have access to this information, then we will 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 as one of their customers, 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 Surveys and Forums.

Information We Collect When You Visit Our Website

When you interact with our Website, 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 activity and to collect Website data. Specifically, when you visit our Website 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 Website, browser referral header or other mechanism by which you came to our Website, and links clicked on in our Website. We may combine this information with other personal information that you provide to us by using the Website.

In the following paragraphs, we provide additional information about our use of tracking devices:

Cookies

When you access our Website, we use cookies. Cookies are alphanumeric identifiers that we (and other third party website 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 Website.

Some of the cookies we use are essential for parts of our Website to operate and have already been set.

You may delete and block all cookies from our Website (most web browsers allow some control of most cookies through the browser settings), but you may not be able to access all or parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon you visit our Website. 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.

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 future. The Help portion of the toolbar 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. Website visitors who disable their web browsers’ ability to accept cookies will be able to browse the Website; however, you must enable cookies to use most of our Services.

Currently, our systems do not respond to browser do-not-track signals.

Clear Gifs (Web Beacons/Web Bugs)

We or the third parties we engage to track and analyze Website data may employ clear gifs (a.k.a. Web Beacons/Web Bugs) to help us better manage content on the Website. Clear gifs 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, clear gifs are embedded invisibly on Web pages. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

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 Website. We use your IP address for the purposes described in this privacy policy, to help diagnose problems with our server, and to administer the Website. 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 Website, 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 Surveys and Forums,” we use the information that we collect from you through your participation in our Services, including our Surveys and Forums for the following purposes:

We may combine all of the information that you submit through our Website, 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 responses to our Surveys and Forums. Below we describe what information we share with Business Subscribers.

As described above, we also 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, not this one.

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 contact us using the details below.

Sharing your Information

We may share information about you as described herein.

Site Users:

If you choose to participate in our Surveys and Forums, we will share the information with the Business Subscriber for whom we are acting as a data processor. This will include your responses to the Surveys and Forums, as well as your contact information and profile information, unless you participated in our Surveys and Forums 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 Surveys and Forums, then the information that you submit also may be subject to that privacy policy. The Business Subscribers may contact you directly if you respond to our Surveys and Forums unless you respond on an anonymous basis.

Partners And Subsidiaries/Vendor Companies:

We may disclose your personal information to our holding company, subsidiaries or affiliates and 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 Surveys and Forums, 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 such information. Our partners and subsidiaries will use your information consistent with the purposes described in this Policy.

Other Visitors to our Website:

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

icanmakeitbetter reserves the right to disclose your information if it licenses, sells, or otherwise transfers its technology or business, or a portion thereof, to third parties, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving us.

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.

Additional Information About Surveys and Forums

We administer Surveys and Forums on behalf of our Business Subscribers, where we act as our Business Subscribers’ data processor. We may create the Surveys and Forums on behalf of the Business Subscriber, or the Business Subscriber will create the Surveys and Forums itself, and provide to us to administer. Regardless of which entity authors the Surveys and Forums, we will host the Surveys and Forums on our Website and collect the responses that you submit. Your participation in our Site Activity (e.g., completing surveys, forum/blog responses, votes, ideas, comments, etc.) will be shared with the Business Subscriber.

In some circumstances, we also will analyze the data and provide that analysis to the company, and in other situations, we turn the survey responses in their entirety to the company. We do not share your individual survey responses with any person or entity other than the company 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.

Please note that we also will provide the Business Subscriber with your profile information, subject to the exception below pertaining to anonymous information. If you have any questions about how your information will be treated, please contact us at the email address listed below. We are not responsible for any information that you submit through this website. If the Business Subscriber invited you to participate in our Surveys and Forums, then that Business Subscriber may have its own privacy policy, which will govern the collection and use of your information.

Whether your participation response to a particular Survey or Forum is anonymous depends upon the Business Subscriber. Some Surveys and Forums will permit you to respond anonymously, whereas other Surveys and Forums will require your name. We will notify you on the Surveys and Forums if you are required to provide personal information in order to participate in a Survey or Forum.

We do not sell your responses to Surveys and Forums to third parties. We may, however, transfer your information (e.g., contact/profile information) to a third party in the event of a transfer, corporate reorganization, bankruptcy, or other similar event, but we will not sell your survey responses under any circumstances. We merely act as a custodian for your responses on behalf of the Business Subscriber.

Third Party Sites

Please note that the Website may, from time to time, contain links to other third party websites 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 these policies. Please review these policies before you disclose any personal information when visiting such third party websites.

Security

We take precautions to ensure the security of your personal information. However, we cannot guarantee that hackers or unauthorized persons may gain access to your personal information despite our efforts.

We cannot protect, nor does this Policy apply to, any information that you transmit to other users. You should never transmit personal or identifying information 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 information from persons under 18 years of age.

User Generated Content

Portions of our Website permit users to engage in Surveys and Forums and are therefore not confidential and are specifically available for public viewing. 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 becomes public information. 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 theterms 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 Rights Under GDPR

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, EU data subjects have certain rights in relation to your personal information:

Right to access Personal Information

You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of; (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.

Right to rectify or erase personal information

You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it.

You can also request that we erase your personal information in limited circumstances where:

We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:

Right to restrict the processing of your personal information

You can ask us to restrict your personal information, but only where:

We can continue to use your personal information following a request for restriction, where:

Right to transfer your Personal Information

You can ask us to provide your personal information to you in a structured, commonly used, machine- readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:

Right to object to the processing of your personal information

You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.

If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Right to object to how we use your personal information for direct marketing purposes

You can request that we change the manner in which we contact you for marketing purposes.

You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.

If you would like us to stop sending promotional communications to your email address, you may opt out of receiving them by following the "unsubscribe" instructions at the bottom of each communication.

You may opt out of the use of your information for analytics by downloading the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout.

Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction

You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union.

We may redact data transfer agreements to protect commercial terms.

Right to lodge a complaint with your local supervisory authority

You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information.

We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

If you would like to exercise any of the rights described above, please send a request to the address or email provided in the Contacting Us section below. In your message, please indicate the right you would like to exercise and the information that you would like to access, review, correct or delete.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

You can exercise your rights by contacting us using the contact details set out below. Subject to legal and other permissible considerations, we will make reasonable efforts to honor your request promptly or inform you if we require further information in order to fulfil your request.

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

If we process your personal information on behalf of our Business Subscribers (as a data processor), you should first contact the Business Subscriber, who is the controller of your personal information, to exercise your rights. We will work with our customers to provide individuals the necessary access about what personal information is processed.

Privacy Shield Frameworks

We and certain other affiliates of Lieberman Research Worldwide, LLC, 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 approved Standard Contractual Clauses, or by relying on certification schemes such as the EU - US Privacy Shield.

Lieberman Research Worldwide complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield. LRW has certified that it adheres to the Privacy Shield Principles with respect to such data. We are a “Covered Entity” under LRW’s Privacy Shield certifications. If there is any conflict between the policies in this privacy policy and data subject rights under 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 https://www.privacyshield.gov/

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, LRW and all of its Covered Entities, including Sentient Services LP, are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to Legal@LRWonline.com. If requested to remove data, we will respond within a reasonable timeframe.

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.

We will also provide an individual opt-out or opt-in choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To limit the use and disclosure of your personal information, please submit a written request to Legal@LRWonline.com.

Please refer to the above section Sharing Your Information for a description of how we share your information with third parties. We contractually require third parties to whom we transfer personal information to provide the same level of protections as set forth in this policy. 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.

Our accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, we remain responsible and liable under the Privacy Shield 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 prove that we are not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, LRW and its Covered Entities, including us, commit to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact our Privacy Officer at Legal@LRWonline.com. We will work to resolve your issue as quickly as possible.

LRW has further committed, for itself and its Covered Entities including us, to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

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.

Contact Us & Questions

Any questions about this Privacy Policy should be addressed to Legal@LRWonline.com or by mail at:

icanmakeitbetter.com
c/o LRW
1900 Ave of the Stars, 16th Floor
Los Angeles, CA 90067
Attn: Privacy Officer