Privacy
Policy
Introduction.
This Information Usage, Privacy & Security Policy ("Policy")
covers personally identifying information ("PII"
or "information") collected through paidsurveytopia.com ("Site")
or any site powered by Thinkaction.com. "You"
means a user of this Site.
Description
of Our Business.
Our business is based on the collection of information, directly or indirectly,
from you. We, or others to whom we transfer it, share it in the United States
and all over the world with third parties who want to know what you think, want
to interest you in something such as a product or service, or who simply get
some kind of credit for contacting you or having you contact them (collectively,
"Third Party Marketers" or "TPMs").
TPMs include but are not limited to our affiliate Greenfield Online
("GO"),
an Internet survey provider. Sometimes we try to match you to a TPM who is
looking for someone like you.
We
let you consider opportunities from TPMs in two basic ways:
-
1.First,
we take registration information from you and then see if you might match or
be interested in opportunities with GO or from a small number of TPMs; and
-
2.Second,
if you aren't interested in anything we showed you, we transfer you to the
website of a type of TPM that we call a third party "gatekeeper"
("TPG"),
i.e., a company whose business is to find a larger world of TPMs in which you
might be interested; we also transfer some of your profile information with
the TPGs so that they can try to figure out what TPM opportunities you might
want to find out about.
In
either case, if you click on a TPM opportunity we will count that as your
instruction for us to forward on your behalf, some of your profile information
to those TPMs as well as any additional information that you enter in connection
with a particular opportunity.
When
you are on a TPG's site, or if you decide to deal with a TPM who contacts you,
read their respective privacy policies to learn what information they collect
and what may happen to it and the other PII that we transferred to either of
them. This is important because once we implement your instruction to transfer
your PII to the TPM, it is, effectively, out of our control even if there are
restrictions between us and any TPM. Any such restrictions do not prohibit the
above or the other business practices described in this Policy, and in any
event, we cannot make TPMs (including TPGs) comply with their contracts and we
do not take any responsibility for any noncompliance by them.
You
might be a marketer's dream, but if you do not want to receive on a regular
basis ads or opportunities (such as to take surveys), or if you are not
comfortable with having us transfer your PII to TPGs and numerous TPMs, or with
having them possibly transfer it to still more people, then this Site is not for
you and you should exit now. When you use our Site (or a TPG or TPM site, or
otherwise deal with any of us) and are affirmatively asked for PII, do not
provide any PII that you do not want provided to TPGs, TPMs and their
transferees.
How
does this Policy relate to my use of the Site?
This Policy is part of and incorporated into our Terms of Use, the contract
between you and us that governs this Site. That means provisions of those terms
impact this Policy, so if you have not read the Terms
of Use,
read them now by clicking on the link.
Who
We Are; Contacting Us & Our Address for Legal Notices; Notices to
You.
We are ThinkAction ("ThinkAction",
"Site",
"we",
"us"
or "our")
a division of Greenfield Online, Inc. ("GO") (although we may be changing our
organization form to become a subsidiary or other affiliate). Our telephone
number is 203-834- 8585 and for customer service matters you may email us at
security@thinkaction.com
To send us a legal notice, mail it by certified mail (return receipt requested)
at: ThinkAction.com, 21 River Road, Wilton, CT 06897, U.S.A., Attn. Legal
Department and General Counsel ("Our
Address for Legal Notices").
When we need to contact you, including when we give a legal notice, you agree
that we may give it to a postal or email address that we have for you and/or may
post notice on the Site. It is important for you to update your address
information periodically.
Your
Agreement with Us.
By providing PII or other information to us or by using our site, you: (i) agree
to this policy, including (without limitation) all of the above and below, (ii)
agree that we may rely without liability on your instructions (such as by
clicking on TPM opportunities) to Disclose (as defined below) your PII,
including but not limited to transfers of it in and out of the U.S. and other
countries by us, our affiliates, TPGs, TPMs, advertisers and transferees of any
of the foregoing; and (iii) acknowledge that if privacy is of concern to you,
you will investigate the privacy policies of TPGs and other TPMs and of
providers of advertisements on our Site.
Information
We Collect That You Do Not Affirmatively Provide.
Our Site contains cookies or other tracking mechanisms placed there by us or
TPMs (cookies are a small file our Site transfers to your computer's hard disk
to allow our server to "remember" specific information, e.g., to insert your PII
so you can avoid retyping). We use persistent, identifying cookies to remember
your information and to link your activities to you. Our cookies collect at
least the following:
-
1.the
domain name and host from which you access the Internet and the Internet
address of the site from which you direct-linked to ours;
-
2.the
date and time you access the Site and pages you visit;
-
3.your
computer's IP address and information about its operating system, and the Web
browser you use; and
-
4.information
to combat fraud or misuse.
While
you can take steps to disable cookies, if you do, the Site won't function as we
have designed it. In our e-mails to you, we use "pixel tags" to determine if
your email software or service can display html-formatted e-mail (this helps us
optimize the size of our e-mail messages and conserve bandwidth). TPM pixel tags
might also be present on our Site or in their email messages. We may also
collect public and non-public information from you or third parties, and combine
it with PII collected through the Site.
Some
TPMs might use their cookies on our Site or in their messages to you. If you
click on an advertisement, for example, a cookie might be placed on your
computer. The same thing can happen if you click on an opportunity from a TPG or
TPM, so you should read their privacy policies.
Information
Collected Via Advertisements.
We work with third parties to provide ads and promotions through the Site and to
assist us in managing customer information and to communicate with you. These
parties include, but are not limited to Avenue A [ www.avenuea-razorfish.com/ ],
Advertising.com [www.advertising.com/] and DoubleClick.net [
www.doublecclick.net ] To find out how these kinds of companies tend to collect
and use PII, click on the links to their websites and review their privacy
policies. We do not control these or other advertising companies or their
privacy policies; also, their practices and policies may change from time to
time. In short, you may wish to visit their sites periodically to check their
policies.
Information
We Collect That You Do Affirmatively Provide.
During registration or in connection with particular TPM opportunities, we
collect basic and some very detailed PII when you are willing to provide it.
Don't affirmatively provide any PII that you don't want to be widely shared or
that you are not legally authorized to provide. The more information you
provide, the better we or a TPG may match you with TPMs (when matching is
relevant),
but it is your choice whether to provide that PII.
If you decide not to provide it to us, we will simply try to match or share the
PII that you do give us (although there will be some PII that we require, in
which case your choice will be to provide it or not to participate).
categories
to
see the kinds of PII that we
tend to ask you to provide; TPGs and other TPMS may ask you to provide different
categories of information so you need to read their policies.
Information
We Do Not Collect.
We don't collect payment information and if anyone tells you that we need it,
don't believe them. For example, we do not collect credit or debit card
information, any financial account numbers or other account access information,
or full Social Security numbers (except in the limited circumstances described
in the next paragraph). Please contactmailto:security@thinkaction.com
immediately should you receive a request for such information from a source that
suggests we are involved. If a TPG or TPM asks for this type of information, you
will need to decide whether to provide it based on the type of transaction in
which you are engaging.
We
will collect your social security number if you win a sweepstakes or earn
incentives and we are required to include your SSN in reporting the value of
rewards you have earned to government or taxing authorities. Then, your receipt
of the incentive or reward is conditioned on providing your SSN.
Children.
TPMs are very interested in information relating to children and many products
and services are offered to families with children. Accordingly, we may ask for
information about children but we do not want to collect it from them. Do not
provide us any PII unless you are at least 13 years of age. If a child under 13
has provided PII, a parent or guardian may so inform us by writing us at our
Address for Legal Notices and we will use commercially reasonable efforts to
delete it from our database, subject to applicable law and this Policy. For more
information about children's privacy on the internet, you may wish to visit
http://www.ftc.gov/bcp/conline/edcams/kidzprivacy/index.html
to learn about some commercially available Internet protection
measures.
What
We Will Not Do with The PII We Collect.
This Policy reveals that we make wide use of PII, but here's what we will not do
with it (subject to applicable law): we will not simply sell or transfer your
PII without regard to this Policy or the business we describe in it. Instead, we
will provide PII to TPGs and other TPMs as described in this Policy (as now
existing or later amended). What we will or won't do, however, is not the end of
the story. At least one TPG for example, reserves the right in its privacy
policy to use the PII we disclose to it for any legally permissible purpose in
its sole discretion. So as we've said, if you don't want wide use of your PII,
do not use this Site or supply the PII to us or a TPG or other TPM.
What
We Tend to Do with The PII We Collect.
We reserve the right to do the above and the following worldwide with PII we
collect (except for what we said above that we will not do): use, access (or bar
access to), process, disclose, display, share, transfer, store, sell, lease,
retain, commingle, investigate, verify, prove and otherwise deal with PII,
voluntarily or as required by and subject to law (collectively "Disclose").
-
•We
automatically (and usually right away) Disclose PII to GO so that it may
consider whether to tell you about a survey for one its customers. If it does,
GO will contact you. If you decide to participate, all of your subsequent
dealings with (and additional information you provide to) GO will be pursuant
to the GO terms of use and its privacy policy instead of ours.
-
•We
will show you a list of opportunities from a limited number of TPMs; if you
don't deal with GO or don't click on one of those opportunities, then we will
transfer you to a TPG site where you can see more TPM opportunities. We will
already have given the TPG some of your profile PII so that, for example, it
can decide what opportunities to show you. The information that we typically
provide to TPGs is shown in red in the Categories list.
-
•If
you click on any TPM opportunity, you may be asked to provide more PII. You
will know what that extra PII is because you will need to enter it. If you
click on any TPM opportunity, we will count that as your instruction for us to
forward on your behalf, some of your profile information to those TPMs as well
as (i) any additional PII that you enter in connection with a particular
opportunity, and (ii) information that the TPM might subsequently request from
us that we have in your registration information. Typically, we will not keep
a copy of the extra PII that you provide in response to particular TPM
opportunities, although we reserve the right to do so; the TPM to whom PII is
sent, however, might keep both the extra information and the registration
information that we send.
-
•You
might hear from a TPM by telephone, e-mail, postal mail, or our Site might
transfer you to a TPG.
-
oYou
have no obligation to deal with any TPM, including TPGs. You will need to
decide whether to deal with the TPM and whether to provide any additional
PII in connection with a TPM opportunity. The part of your registration
information that is sent to the TPM, and any additional PII that you enter
in connection with a TPM opportunity, will be subject to any TPM privacy
policy or other agreements or the TPG and/or relating to your dealings with
any TPMs. When you are on the TPG's page, there should be a link to the
TPG's privacy policy – read it before you click on a TPM opportunity.
-
oThis
Policy only applies to your dealings with us and only to the PII that we
keep. Once we Disclose PII to a TPM, we effectively lose control of it even
though we will contract with TPGs, for example. However, contracts do not
ensure performance, we cannot make TPGs or other TPMs comply with their
contracts, and we do not take any responsibility for any noncompliance by
them. Accordingly, do not provide any PII on our Site or to a TPG or other
TPM that you would not want a TPM to be able to use under a "worst case"
policy that a TPM might have.
-
•We
store the information you provide during registration so that we can
periodically see if there's a match to TPM opportunities or surveys, or in
case a new TPM would like to see your PII. The TPGs may store it for as long
as they think they need it for their business.
-
•We
Disclose PII to third party service providers (such as emailers etc.) to
enable them to provide services to or for us, and we Disclose PII to enforce,
actual or potential transactions, contests, requests, actions, applications,
and rights and defenses.
-
•We
use IP addresses collected by cookies to analyze trends, administer the Site,
track visitor traffic, and aggregate demographic data. We also link IP
addresses to PII so that we can automatically fill out forms for you when you
visit.
-
•We
treat PII as our asset and Disclose it and other assets to third parties,
including (without limitation) in sales, mergers, consolidations, changes of
control, transfers of assets, reorganizations or liquidations and the like.
TPGs or other TPMs may also consider the PII that they receive to be an asset
that they own.
-
•We
Disclose PII to anyone as required or as we think advisable (in our sole
discretion) under applicable or potentially applicable laws (e.g., subpoenas
and so on). We also Disclose it to verify with whom we or a TPM is dealing and
to comply (voluntarily or involuntarily) with requests of governmental or law
enforcement officials.
-
•Without
undertaking a duty to do so, we may Disclose PII: to prevent economic or
personal loss or damage to anyone (including ourselves) or to prevent fraud or
unauthorized use of PII or the Site; or when we think Disclosure might help
protect, defend or enforce rights and property of ours or anyone else.
It
is impossible to list every lawful use that can be made of information and the
above is not intended to do so. It is only a general description and we reserve
all rights to make other lawful uses of PII.
Your
Control Over Further Disclosures By Us
If
you no longer want to receive emails from us or do not want us to continue
providing PII to TPMs, you may click on the unsubscribe link contained within an
e-mail message from us, or you may contact us via e-mail atmailto:Unsubscribe@ThinkAction.com
or write us at Our Address for Legal Notices with a request to be unsubscribed.
Unsubscription requests are usually processed within 72 hours and you may
receive additional emails during this processing time. To stop receiving emails
from a TPM to whom we Disclosed PII before you unsubscribed, you will need to
follow their directions for unsubscribing -- unsubscribing from our list will
not remove you from other lists. Unsubscribing does not result in deletion of
your PII from our database. In normal practice we tend to delete PII about two
years after it is first entered, but even after deletion, we retain some of it
for administrative purposes (such as your name and when you first registered).
Also, if we think retention of more PII is necessary or useful for some other
reason; we reserve the right to retain it.
If
you are a resident of California or another state with a law requiring us to
provide the following information, once a year you may ask us to provide you
with a list of: the standardized categories of information we disclosed to TPMs
for their direct marketing purposes during the immediately preceding calendar
year, and the names and addresses of those TPMs and the nature of their
business, all as and if required. To request this information, write us at Our
Address For Legal Notices.
Security.
With respect to security of PII when it is in our database (your registration
information, for example), we attempt to protect that PII from unauthorized
access by taking several steps. For example, (i) we restrict access to PII to
employees who need access in order for them to do their jobs. These employees
are limited in number and we have privacy and security policies that apply to
them; and (ii) the servers on which we store PII have physical and electronic
security intended to create what we believe is commercially reasonable security.
We do not encrypt stored or transmitted PII. Nevertheless, we
do not guarantee security.
Neither people nor security systems are foolproof, and people can make mistakes,
commit intentional crimes, or fail to follow policies or contracts.
Your
e-mails to us are not necessarily secure against interception so do not include
sensitive information in them – we generally will not ask for sensitive
information (such as passwords and financial account numbers) and you should
assume that if you get such a request, it might be fraudulent.
You
agree promptly to notify us via e-mail at webmaster@thinkaction.com
if your password is lost, stolen or used without permission.
Your
Consent to Electronic Notice If There is a Security Breach:
If we are required to disclose or provide notice of unauthorized access to or
other invasions of certain security systems, you agree that we may do so when
required (and when we voluntarily wish to provide notice) by either posting
notice on our Site or giving notice to any email address we have for you, in our
good faith discretion.
Identity
Theft.
If any person believes they are a victim of identity theft entitled by law to
request information from us, write us at Our Address For Legal Notices and we
will explain what additional information must be provided to us. After we have
received that information, we will supply (without charge) the information
legally required to be disclosed that we then have, subject to applicable law
and reserving all of our rights and defenses.
Links.
This Site contains links to other sites, including sites of TPGs or others. The
links are provided to connect you to TPGs or other TPMs or for your convenience
– but we do not endorse those sites and have no liability for them (including
without limitation, for their privacy policies or their products or services).
Also, those sites (or the companies that run them) are not our partners or
agents no matter what they say. Any dealings with a TPG or other TPM or solely
with them, not us.
Your
Ability to Update PII.
Our business depends upon the accuracy, currency and reliability of your
information, as does your ability to participate in some programs or surveys. In
our Terms of Use, you also agree that if you provide information it will be
accurate. To keep that promise and to improve your chances of participating in a
wider range of opportunities, you agree to update your information as allowed on
our Site. We do not maintain all PII in a form that can be updated and we may
keep a record of changes (including deletions) and Disclose them for any lawful
purpose. We may also determine what may be changed (e.g., if we are required to
keep track of certain kinds of actions, you may not change relevant
information).
Amendments.
We will be changing what we do and how and why we Disclose data periodically –
this Policy describes what we currently envision but that will change. You agree
that we may amend all or part of this Policy from time to time in our
discretion. You also agree that we may give notice of an amended version by
posting notice on the Site's homepage thirty (30) days prior to the effective
date of the amended version; or we may give notice by another method, including
(without limitation) by email. You agree to check the home page periodically for
notice of an amended version and to review that version. All amended versions
will apply retroactively to all PII we have before and after the effective date
(and until the next amended version takes effect). You agree that Using
the site or accepting a TPM opportunity after the effective date of the amended
version, or failing to unsubscribe by the effective date, will constitute your
agreement to the amended version.
If you do not want to agree to an amended version, make sure that you (i)
unsubscribe before its effective date by sending an email to Unsubscribe@ThinkAction.com
or writing us at Our Address for Legal Notices; and (ii) do not use the Site or
accept an opportunity from a TPM after the effective date.
Information
About Enforcement of Our Policy.
This Policy is part of the Site Terms of Use. If there is an inconsistency
between the Terms of Use and this Policy, the latest version of this Policy will
control. As a contract, we and you are bound by this Policy. If you think we are
in default, you may contact us by sending an e-mail to Our Address For Legal
Notices. There are no third party beneficiaries of this Policy.