Privacy Policy

Bellomy Research, Inc. Privacy Policy   

Effective Date: November 1, 2020
Last Reviewed On: July 8, 2021

This privacy policy (“Policy”) is applicable to the www.bellomy.com site (the “Site”) and data generally collected by Bellomy Research, Inc.

Please note that individual study privacy conditions may vary. Any variances from this Policy will be clearly noted for your review as set forth below and our SmartLab site has its own Privacy Policy.

Bellomy adopts this Policy in accordance with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Policy.

Purpose for data collection

Bellomy is a full-service market intelligence firm that provides strategic insight, knowledge, and direction to some of the most respected organizations in the US. Since 1976, Bellomy has been providing consumers like you the ability to voice opinions by participating in research surveys, focus groups, and online communities and panels. As a research participant, your opinions help inform the development and improvement of new products and services, customer service programs, and public and social policies.

We conduct research for the benefit of our clients, who include for-profit companies, nonprofit organizations, and governmental institutions.

When you participate in research with us or otherwise provide us your Personal Information (defined below), these principles apply:

  • We will not share your Personal Information with unaffiliated third parties without your consent unless required by law (situations described below).
  • Your survey responses are confidential and not attributed to you in client reports unless you permit otherwise by written consent.
  • We will not share or sell your contact information to anyone.
  • We will not present you with offers for our clients' products or services unless you permit otherwise by written consent.
  • Occasionally, we may re-contact you to validate your responses. We will not misrepresent ourselves or what we are doing in such cases.
  • Your participation in a study is voluntary and your decisions will be respected.

If you have any questions about this Policy, please contact privacy@bellomy.com or via telephone at 800.443.7344

Information we collect

Bellomy collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). Personal information does not include:

  • Publicly available information from government records;
  • Deidentified or aggregated consumer information;
  • Health or medical information covered by the Health Insurance Portability and Accountability Act and the California Confidentiality of Medical Information Act; or
  • Personal information covered by various privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act or the California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994.

When you participate in our surveys, we may ask you for your opinions and also your Personal Information, such as your age and household composition. You may refuse to answer certain questions or discontinue participation in a study at any time. If you join one of our research panels, you may discontinue your membership at any point after joining by following the opt-out process for that particular panel.

In particular, Bellomy has collected the following categories of Personal Information from its individuals within the past 12 months:

 

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

YES

B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

 

Some Personal Information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

 

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

YES

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

YES

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

NO

G. Geolocation data.

Physical location or movements.

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

YES

 

Bellomy obtains the categories of Personal Information set forth above from the following sources:

  • Directly from you. For example, from forms or surveys you complete.

When our interviewers reach respondents by telephone or in person, they identify themselves and state the purpose(s) of their contact. Our mail-delivered or emailed survey invitations clearly identify us as Bellomy and explain the purpose(s) of our contact.

When we contact you, we will generally do so for one of the following purposes:

  • To invite you to join a survey research panel;
  • To conduct a survey research interview;
  • To validate answers you gave in a survey we conducted;
  • To update our records on the accuracy of your personal information.

Occasionally, we may contact you for one of these other purposes:

  • To notify you if you have won a sweepstakes conducted on behalf of our client;
  • To ask for your permission to use your Personal Information for a purpose that was not identified to you when we first collected your Personal Information.

Use of Personal Information

Bellomy may use or disclose the Personal Information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, reporting your survey responses.
  • To provide, support, personalize, and develop the Bellomy web site, products and services.
  • To create maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize and enhance your Bellomy web site experience.
  • To help maintain the safety, security, and integrity of the Bellomy web site, products and services, databases, and other technology assets, and business.
  • For testing, research, analysis and product development, including to develop and improve the Bellomy web site and our clients’ products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your Personal Information.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our consumers is among the assets transferred.

Information we share or transfer

Your survey responses are confidentially handled. We generally combine your survey responses in a given survey with the responses of others who participate and report the aggregated responses (without identifying the individual respondents) to the client that commissioned the study. 

Some types of research require individual respondent identities to be shared with the commissioning client. You will be informed before choosing to participate in such a study and we will only provide respondent identities with written consent.

The only exceptions when we may disclose your Personal Information or survey responses to unaffiliated third parties are as follows:

  • You consent to sharing your Personal Information and individual responses with an unaffiliated third party for a specified purpose;
  • In accordance with industry guidelines, we work with a third party service provider who is contractually bound to keep the disclosed Personal Information in a confidential and protected manner and use it only for research or statistical purposes;
  • In the rare but possible circumstance that the Personal Information is subject to disclosure pursuant to a subpoena, or similar legal process, or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety, or the safety of others, investigate fraud, or respond to a government request;
  • To conduct research operations such as data processing and for incentive or rewards fulfillment in relevant situations.

Where we share your Personal Information or survey responses with our affiliated companies or non-affiliated service providers (both within and outside the United States) for survey research operations or incentive fulfillment, they are contractually bound to keep such information confidential and to protect it with reasonable security standards and practices. We enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for performing the contract.

Your Personal Information may be transferred if Bellomy is involved in a merger, acquisition, or sale of all or a portion of its assets. In such cases, the receiving entity would be required to comply with our privacy policy requirements.

We may share your Personal Information with the following categories of third parties:

  • Service providers to execute research study surveys and distribute incentive rewards.
  • Clients, to the extent necessary to fulfill our business purpose as a service provider.

In the preceding 12 months, Bellomy has disclosed the following categories of Personal Information for a business purpose:

  • Category A: Identifiers.
  • Category K: Inferences drawn from other personal information.

We disclose your Personal Information for a business purpose to the following categories of third parties:

In the preceding 12 months, Bellomy has not sold Personal Information.

Security of personal information

We have put in place reasonable administrative, technical, and physical safeguards to protect against unauthorized access to the information we collect. However, no security measures are 100% impregnable and we cannot guarantee against all potential security breaches. Moreover, the transmission of information over the Internet is not inherently secure, and we are not responsible for the transmission of information over networks that we do not control. Your use of our services demonstrates your assumption of these risks. If you have any questions about security of our services, you may contact us at the email address or the toll-free telephone number indicated above.

Accuracy of personal information

We make reasonable efforts to keep Personal Information in our possession and in use on an ongoing basis, accurate and complete. In many cases, we rely on our respondents, such as panel members, to keep their Personal Information accurate and complete.

Unsolicited email or SPAM

We do not intentionally "spam" email addresses to seek their participation in surveys. Rather, we send e-mail invitations only to people who we believe have "opted in" (i.e., affirmatively agreed to receive invitations) to our communications.

We will give every person who receives an email invitation the opportunity to "opt out" of that invitation and all future emails.

We do not knowingly invite children under the age of 13 to participate in research studies without taking measures to obtain parental consent.

Cookies

We use cookies (small text files placed on your browser) to facilitate online surveys. These cookies do not contain Personal Information. The cookies we use enable you to navigate the online platform and help us refresh your account if you are a returning panelist. 

As is true of most Web sites, we gather certain information automatically. This information includes internet protocol (IP) addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data. During this process, we may also collect limited information about your system configuration such as screen resolution and video color depth in order to determine the best possible presentation. This information will never be released to a third party and is only used to match you with the appropriate surveys. The cookies we use do not collect information from other sites you may visit.

Access to Personal Information, data portability, and deletion rights

Access to specific information and data portability rights

You have the right to request that Bellomy disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of Personal Information we collected about you.
  • The categories of sources for the Personal Information we collected about you.
  • Our business or commercial purpose for collecting or selling that Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • The specific pieces of Personal Information we collected about you (also called a data portability request).
  • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
    • Sales, identifying the Personal Information categories that each category of recipient purchased; and
    • Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
  • If we are unable to disclose any of the above information, we will provide you with a detailed explanation.
Deletion request rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny a deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise preform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code Section 1546 et. seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

If we deny a deletion request, we will provide you with a detailed explanation.

Exercising access, data portability, and deletion rights

To exercise the access, data portability, and deletion rights set forth above, we ask that you submit your request in writing to this email address: privacy@bellomy.com or via telephone at the following toll-free number 800.443.7344.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent,  complete the form located here (link) and submit it to Privacy @bellomy.com.

You may only make a verifiable consumer request for access or data portability two times within a 12-month period. The verifiable request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, which may include:

Name first, middle initial, last
Street address
City, state, zip
Phone area code, number, extension
Email address.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

You may be able to access your Personal Information and correct, amend, or delete it where it is inaccurate, except as set forth above and as follows:

  • The burden or expense of providing access would be disproportionate to the risks to your privacy in a given, individual case;
  • Providing access to your personal information would be likely to reveal personal information about others;
  • Disclosing the information would reveal confidential information about our clients.

We will respond to your request within 45 days of receiving it. If we require more time we will inform you of the reason and extension period. If we cannot fulfill your request, we will provide you an explanation for it. If you have an account with us, we will deliver the written notice or explanation to that account. If you do not have an account with us, we will deliver by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of the verifiable consumer request. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another without hindrance.

Personal information sales opt-out and opt-in rights

California consumers have the right to direct companies that are subject to the CCPA to not sell your Personal Information at any time if those companies sell Personal Information (the “right to opt-out”).  However, we do not sell Personal Information.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you with a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. You will have an opportunity to review any incentive terms prior to opting into participation.

Data retention

We will retain the personally identifiable information described above for as long as the information has value as part of the services we offer, or as long as is necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, whichever is longer. If you wish to request that we no longer use your Personal Information in our services, please email us at privacy@bellomy.com or call via telephone at the following toll-free telephone number 800.443.7344

Links to other sites

If you visit a third party website that is linked from our site, you should read that site's privacy policy before providing any personally identifiable information. We are not responsible for the practices of such third party websites, and a link to such website is not an endorsement by us of such website's privacy practices, products or services.

Notification of material changes to this policy

If we make a material change to this Policy or our privacy practices, we will post a prominent notice on our website for 30 calendar days prior to the implementation of the material change and describe how individuals may exercise any applicable choice. The change would not apply to Personal Information that is collected prior to the change unless consent is obtained. At the time of implementation of the material change, we will record the timing of the revision at the introduction of this Policy. Your continued use of our web site following the posting of changes constitutes your acceptance of such changes.

How to reach us

Questions regarding this Policy, the practices of Bellomy, or your access, data portability and deletion requests should be directed via email to privacy@bellomy.com or via telephone at 800.443.7344

 

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