ENGINE INTERNATIONAL, INC. – PRIVACY NOTICE

Welcome to the privacy policy of Engine International, Inc. (“Engine Insights” or “ENGINE”). We provide market opinion and social research. You have the right to know what data we collect and the business purposes for which we use that information. You also have the right to opt-out of our sale of information (as applicable) without penalty. Engine Insights adheres to applicable privacy laws and conducts its business in accordance with best practices as set forth by the Insights Association (IA) and members of the European Society for Opinion and Marketing Research (ESOMAR). For more information about what we collect, and your privacy choices, please find the full privacy policy below.

What data does ENGINE collect?
Engine Insights collects data pursuant to market research surveys which we conduct on behalf of our clients. The categories of data we collect may include: a) PII such as email address, telephone number and postal address, b) pseudonymous information collected from your browser or device such as IP address, HTTP cookie ID, information about the website you were on prior to taking our survey, the city and state you are located in, browser type, computer, device operating system type and other weblog information. We may append demographic information onto that data such as your race, gender and income range. Some of this information is inferred, and some is available via publicly available sources. We may obtain additional insights about your browser or device from third party ad networks and data brokers that pass us pseudonymous information. We collect and aggregate survey responses and give a summary of that information to our clients.

What does ENGINE do with this data?
Engine Insights uses this data to help drive market research programs on behalf of ENGINE’s clients who are seeking to obtain a better understanding of consumer perceptions. These consumer perceptions are often incredibly valuable in helping our clients improve their products and services. We process all of this data in order to inform which questions to ask, and to help our clients make sense of the survey responses. For example, it may be helpful to understand that men and women in general have a different opinion on given topic or with respect to a particular product or service. We send the survey responses to each client, but typically remove PII from the results so as to protect the anonymity of each respondent. The survey responses will contain a pseudonymous ID that does not allow ENGINE or ENGINE’s clients to directly identify a respondent. But the pseudonymous ID is considered personal information in some jurisdictions. We don’t consider the transfer of the results to be a sale of personal information under California law, but we nonetheless want you to understand our process and want you to be able to opt-out in the instances where a sale may be deemed to have taken place.

Third Party Collection and Receipt of Information
Engine Insights partners with third parties who may provide us with data as we conduct these surveys. Some of these third parties may provide us with pseudonymous information in order to give a more complete understanding to our clients of the profile of the survey participants. It is possible that some of these data transfers may be considered a sale of data under California or other applicable privacy laws. In connection with your survey, Engine may also send data about your device to a third-party fraud detection vendor named Imperium. For information about how Imperium uses information to prevent fraud, please see their privacy policy located at https://www.imperium.com/privacy/.

Scope of Privacy Policy

This Privacy Policy applies to ENGINE and not to any of our third-party partners. It also does not apply to the privacy practices of any of our research clients.

Privacy by Design

Our foundation of building a strong privacy framework at ENGINE follows an internal framework of privacy by design. We integrate privacy in strategy, research, surveys, and more. Our internal procedures align our data use practices in a manner that maximizes the innovative benefits of our services in the twenty-first century while keeping consumer privacy at the forefront of our business practices and building infrastructure that is effective to guard the data we are entrusted with. We protect consumer privacy and provide relevant services in the research sector which benefits everyone involved, especially clients and consumers. Ensuring the protection of privacy throughout the entire lifecycle of the data is of the utmost importance and ENGINE is careful to protect privacy as data is collected, used, and destroyed responsibly.

ENGINE has developed a strong privacy foundation and has a company culture aimed at data minimization, pseudonymization and adequate data encryption and security.

How Does Engine Provide Research Services?

We partner with businesses whose privacy policies allow them to share information about their customers and/or inquirers as well as information about a consumer’s interests as inferred from their web browser. This information may include the date and time of a visit to their store, website or mobile application, or allow us to visit their stores to obtain consent from their customers to do surveys or send them online through traditional ad space or by email. The information allows us to research and provide our clients more about the things consumers are interested in, allowing businesses to improve their products or services as a result.

Disclosure of Information

We may disclose proprietary, pseudonymous information to our clients for reporting purposes, and we may share aggregated information as well as certain PII such as name, address, email address and transactions with other third parties for analytical and research purposes. We also work with third party agents who are contractually required to use data only to provide services to us. These third-party service providers used by ENGINE include: a) cloud computer, data storage and file storage providers, b) email marketing providers, c) website and b2b sales analytics providers, d) customer relationship management, contact database vendors, data hygiene vendors, survey vendors and project management software providers, e) customer billing systems partners, f) login authentication providers to ensure that the logins to our systems are working efficiently, g) social media platforms for advertising and marketing purposes, h) outsourced computer programmers helping ensure our systems are operating properly, i) auditing, debugging and security vendors.

ENGINE may also need to disclose information if (1) we believe that there has been a violation of the law, of your rights, or of our rights, (2) to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements, or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law, and (3) if our company or substantially all of its assets are acquired.

Engine May Provide Services On The Web

When a consumer engages with an online survey from us, we will obtain consent to utilize a “cookie” or “pixel tag” to be placed on the consumer’s machine by a third-party partner that may collect device identifiers like iOS and Android Unique Identification Number (UID). Information collected from a cookie, UID, or pixel tag are not linked to PII. No PII is transferred in the cookie, UID or pixel tag to a third party. A third party only knows that consumer by a pseudonymous ID.

What Is A “Cookie” Or “Pixel Tag”?

A cookie is an industry-standard small data file placed on a consumer’s computer. Cookies allow websites to “remember you” when you return to their website. Again, no PII is transferred in the ENGINE cookie to a third party. This website and associated surveys may contain, in addition to ENGINE cookies, other third-party cookies that assist us in supplying information that will make it easier for you to navigate on our site. A pixel tag (also commonly known as a web beacon or clear gif) is an industry-standard, often transparent graphic image usually no larger than a 1×1 pixel that is placed in a website or e-mail.

Pixel tags are used by ENGINE to transfer relevant pseudonymous information from this website or a client’s website to third parties associated with us for the purpose of providing additional research and relevant information for clients to use to make their customers’ experiences better. Cookies are used by ENGINE to link this pseudonymous information to non-identified unique users. Pixel tags and cookies may also be used to link additional pseudonymous information provided by a third party.

Data Retention

ENGINE retains data it uses for research purposes for periods determined by our clients, after which the information is removed and discarded. If you have contacted us or provided PII to ENGINE to be contacted or joined our mailing list, we will retain your information for as long as you’re active or as needed to provide you with information.

YOUR CHOICES

We hope that after reading through this Privacy Policy, you agree that ENGINE is collecting and using data responsibly. For some of our surveys, we may request your permission to collect data from your browser. We will not collect that data without your consent. If you do not want data to be collected, please indicate this preference when prompted in the survey.

Upon request, ENGINE will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by contacting us at dpo_US@enginegroup.com. We will respond to your request within a reasonable timeframe. In order to help us to respond promptly to your inquiry or request, please include as much information as you can in your communication with us—such as the reason you believe we hold any of your data, and any other supporting information such as a particular survey or focus group you took part in, or the title of any email you may have received, or the phone number you may have received a call from.

ENGINE may have third parties place survey requests on websites that are part of the Google Display Network. Based on your visits to these websites, Google uses an advertising cookie to associate your browser with interest and demographic categories. Google may then uses these categories for IBA on these websites. To learn more about this and your choices from Google, please click here.

CALIFORNIA DATA SUBJECTS

The California Consumer Privacy Act (CCPA) provides additional privacy protections for California data subjects and users, including: a) the right to see what data we have about you, your computer or device (i.e., the right to know), b) the right to delete the data we have about you, your computer or device (i.e., the right to delete) and c) the right to opt-out of the sale of data about you, your computer or device to certain third parties (i.e., the right to opt-out from sales of your information).

You may access those rights with respect to ENGINE by sending us an email to dpo_US@enginegroup.com or calling us via our toll-free California data subject hotline at 833-457-0281. We will take steps to confirm your request within 10 days and make a good faith attempt to fulfill your request within 45 days. ENGINE does not discriminate against you if you exercise any of the above rights. Please note that we may not be able to honor one or more of these rights if doing so would violate applicable law.

The CCPA defines personal information broadly and as such, it includes pseudonymous identifiers such as cookie IDs and mobile advertising IDs. Under the CCPA, your request to see the personal information that we have about you may include: (1) specific pieces of personal information that we may have about you; (2) categories of personal information we have collected about you; (3) categories of sources from which the personal information is collected; (4) categories of personal information that we sold or disclosed for a business purpose about you; (5) categories of third parties to whom the personal information was disclosed for a business purpose under the CCPA; and (6) the business or commercial purpose for collecting or selling personal information.

We may take reasonable steps to verify your request. We will fulfill requests we are able to verify so long as we are not prohibited from doing so by applicable law and/or the information is not essential for us for billing, fraud prevention or security purposes. We will share our reason(s) for denying your request in the event that we are unable to fulfill your request.

You may make an access or deletion request via an authorized agent. Please note that we will request any authorized agent demonstrate that they have been authorized by you to make a request on your behalf. We may require any authorized agents to provide us with contact details such as an email address and phone number so that we may ensure a timely response.

Safeguarding Information We Collect And Use

The security of your information is important to us. We have implemented appropriate security measures to protect the information in our care, both during transmission and once we receive it. We take reasonable physical and technical security measures to protect our data from unauthorized access, as well as unauthorized disclosure.

Privacy Of Children

We are committed to protecting the privacy of children. We take special care when conducting research with children, as set out in the Insights Association Code of Standards and Ethics.

Changes To This Privacy Policy And How To Contact Us

We may change this Privacy Policy from time to time. When we do, we will post the change(s) on our website. We encourage you to periodically review this page for the latest information on our privacy practices.

Terms & Conditions During Your Visit To The Engine Website

The place of performance for this website is New York. ENGINE makes no representation that materials at this site are appropriate or available for use outside of the United States and access to them from territories where their contents are illegal is prohibited. You are responsible for compliance with local laws in relation to the use of this site outside the United States. The use of this site does not establish any joint venture, partnership, employment, or agency relationship between you and Engine. The Choice of Law is New York. You hereby consent to the jurisdiction and venue in the state and federal courts in New York, NY. Please be aware that ENGINE may provide links to other websites, which if you click on them may collect personal information about you. The information practices of those third-party websites linked to ENGINE are not covered by this Privacy Statement.

Headings are for reference purposes only and in no way define, limit, construe or describe the scope or extent of such section. As a visitor to this website, YOU UNDERSTAND AND CONSENT THAT ANY DISPUTE CONCERNING PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND APPLICABLE SITE TERMS AND CONDITIONS. You also agree that you have provided notice to, and obtained consent from, any third-party individuals whose information you supply to us with regard to: (a) the purposes for which such third party’s information has been collected; (b) the intended recipients or categories of recipients of the third party’s information; (c) which of the third party’s data are obligatory and which data, if any, are voluntary; and (d) how the third party can access and, if necessary, rectify the data held about them. You agree that the English-language version of this Privacy Policy shall be the sole version used in interpreting and enforcing this Privacy Policy.

Your use of this website constitutes your agreement to indemnify ENGINE and its affiliated entities and to hold them harmless from any and all claims and expenses, including attorney’s fees, arising from your use of this website.

YOU AGREE THAT OUR LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE VALUE OF THE TRANSACTIONS OR SERVICES PROVIDED TO YOU BY US TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED BY OUR TERMS AND CONDITIONS.