Privacy, Confidentiality and Anonymity Policy

Privacy, Confidentiality and Anonymity Policy

[Last Updated: February 4, 2021]

Social Pulse Asia (“SP.A,” “we,” “our,” and/or “us”) values the privacy, confidentiality and anonymity of individuals who use our website, fill-up our surveys, access our publications, engage with us on our social media accounts, use our mobile applications, interact our team members and access our related services (collectively, our “Services”).

This Privacy, Confidentiality and Anonymity Policy (the “PCAP”) explains how we collect, use, and share data and information from our community members (“Users,” “Members,” “Respondents,” “Individuals,” “you,” and/or “your”) to facilitate the most effective and efficient use of our Services. By using our Services, you agree to the collection pro, use, disclosure, and procedures this PCAP describes.

Beyond the PCAP, your use of our Services is also subject to our General Terms and Conditions and, more specifically, our Verified Respondent Terms and Conditions.

We process and store your data and information in the servers of Hostwinds which are physically located in three locations: Dallas, Texas, USA; Seattle, USA; and Amsterdam. We neither sell your information to third parties nor share your information with foreign governments except in the limited circumstances described in this PCAP document (see “How We Share the Data and Information We Collect” below for more detail).

Data and Information We Collect

We may collect a variety of data and information from or about you, your mental cognition, your description of various aspects of your life situation from various sources, as described below.

1. Data and Information You Provide to Us. Note here that the data and information listed below may be updated from time to time.

1.1 Registration Information. When you sign up for an account at the SP.A website we may collect data and information such as, but not limited to, your name, residential address, contact information (mobile and landline phone, email address), social media account information, display name, photo.

1.2 Respondent Profile. Individuals who apply to become Verified Respondents at https://socialpulse.asia/surveys/index.php/898162?lang=en are requested to provide various kinds of data and information.

1.3 Cognition Surveys. Verified respondents who answer survey questions on Cognition Surveys are asked to verbalize their thoughts, opinions, ideas, feelings, sentiments, beliefs, awareness and knowledge units regarding a host of topics.

1.4 Life Situation Surveys. Verified respondents who answer survey questions on Life Situation Surveys are asked to verbalize descriptions of various aspects of their life situations.

1.5 Verification Information. As we require all SP.A users, members and respondents to undergo a verification process, we may ask for information that can be used to verify your identity, such as scans of your government-issued photo identification documents or residential address verification documents. When your government-issued photo identification information is no longer necessary to verify your identity, we delete the scans (front and back). We retain only an anonymized hash corresponding to the information the identification document contains, in order to prevent identity theft and impostor accounts. No personally identifiable information from your identification document can be retrieved from the stored hash. In addition to the identification information, we ask for you to take a selfie. We retain the selfie to prevent the creation of impostor accounts, but we store them securely, in encrypted form.

1.6 Content you Share. We collect any data and information you choose to provide on our Services, such as social media posts, follows, reactions (likes, etc), photos, videos, gifs, comments, votes, and echoes.

1.7 Payment Information. If you make a purchase through our Services, your payment-related information, such as your credit and debit card or automated clearing house (ACH) information, is collected and stored by our third-party payment processor on our behalf.

1.8 Communications. If you contact us directly, we may receive additional information about you. For example, if you contact us for customer support, we may receive your name, email address, phone number, the contents of any message or attachments you may send to us, and any other information you choose to provide.

2. Data and Information We Collect When You Use Our Services.

2.1 Device and Location Information. We receive information about the device and software you use to access our Services, including IP address (from which location may be inferred), device type, web browser type, operating system version, phone carrier and manufacturer, member agents, application installations, device identifiers, mobile advertising identifiers, and push notification tokens.

2.2 Usage Information. We automatically receive information about your interactions with our Services, such as the posts or other content you view, the searches you conduct, the people you follow, and the dates and times of your visits.

2.3 Your Contacts. If you permit us to access the address book on your device or give us permission to import your contacts from an email account associated with your account, we may access and store names and contact information from your address book to help you follow your contacts, and your contacts to follow you.

2.4 Information from Cookies and Similar Technologies. We and our third-party partners, such as analytics partners, collect information using cookies, pixel tags, and similar technologies.

Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.

Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from our Services, you may not be able to utilize the features of our Services to their fullest potential.

How We Use the Data and Information We Collect

We may use the data and information we collect:

  • To provide, maintain, and improve our Services;
    • To filter, categorize and group respondents according to requests of various survey commissioners and report users for the purpose of panel formation for further surveys, focus group discussions, group consultations and other targeted group activities;
    • To personalize your experience on our Services, such as by providing tailored content and recommendations;
    • To understand and analyze how you use our Services and develop new products, services, features, and/or functionality;
    • To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
    • For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;
    • To send you text messages and push notifications;
    • To facilitate transactions, redemptions, and payments;
    • To verify your identity and determine your eligibility to join our activities and Services;
    • To find and prevent fraud and respond to trust and safety issues;
    • For compliance purposes, including enforcing our General Terms and Conditions or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
    • For other purposes for which we provide specific notice at the time the information is collected.

The use of your data and information by SP.A is informed by a strict distinction we make between the concepts of privacy, confidentiality and anonymity.

SP.A defines “Privacy” as the right of each individual to decide what aspect of his/her life is to be known and/or accessible to others.

SP.A defines “Confidentiality” as the right of each individual to decide which entity gains knowledge of and access to their data and information.

SP.A defines “Anonymity” as the right of each individual to decide what data and information defined in the section above entitled “Data and Information We Collect When You Use Our Services” is traceable or attributable to personal information (names, residential addresses).

By making an explicit declaration of what data and information of yours that we collect, that we receive, and how we use them, how we share them, and by getting your affirmative express approval for these – by using our Services then you have expressly given your affirmative consent to this PCAP document – then SP.A is fully compliant with your right to “Privacy” as defined above.

SP.A keeps your data and information confidential as it does not share or divulge or display your data and information to any other entity without your affirmative express approval. By using our Services then you have expressly given your affirmative consent to this PCAP document and thus SP.A has complied with your right of “confidentiality” as defined above.

In the ways SP.A uses your data and information (as explicitly defined in the section entitled “How We Use the Data and Information We Collect”) and in the ways SP.A shares your data and information (as explicitly defined in the section below entitled “How We Share the Data and Information We Collect”), we are compliant with your right to anonymity as we do not associate your name or identity documents or residential addresses with any other data or information which you have submitted in our surveys.

The important thing to know here is that your identity, personal and other demographic information is used only for the purposes of establishing the validity, veracity and relevance of survey responses.  Personal thoughts, opinions, sentiments and ideas expressed in your survey responses are reported as aggregate information broken down by demographic groupings.  Your survey responses become more meaningful and useful if they are accompanied by important details such as, for example, age, location, family circumstances and overall life situation.

Names, identity documents and residential addresses are used only in the Respondent Verification Protocol (RVP) .  In absolutely no circumstances are names, identity documents or residential addresses accessible by survey principals (those who commission SP.A to run surveys) nor are they ever listed in survey reports.  This absolute restriction is explicitly declared in our Privacy, Confidentiality and Anonymity Policy.

How We Share the Data and Information We Collect

Publications. SP.A publications include your data and information in summarized and aggregated forms.

Vendors and Service Providers. We may share any data and information we receive with vendors and service providers retained in connection with the provision of our Services.

Content you Share on our Social Media Accounts. Our Services that are disseminated through our social media accounts are social services that allow you to find, enjoy, and share our content. Your display name, display name, profile photo, about me section, and contacts (i.e., members you are following) will always be viewable and/or searchable by other Members. The content you post to our Services will be displayed and viewable by other Members by default. Although this content is public by default, in the “Your Choices” section below, we describe the account settings and controls you can use to limit the sharing of certain information. We are not responsible for other Members’ use of available information, so you should carefully consider whether and what to post and how you identify yourself on our Services.

Marketing. We do not and will never rent, sell, or share information about you with non-affiliated third parties for their direct marketing purposes unless we have your affirmative express consent.

Analytics Partners. We use may use 3rd party analytics services to collect and process certain application analytics data.

As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through our Services.

Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this PCAP document in effect at the time of the acquisition or merger.

Consent. We may also disclose your information with your permission.

Data and Information that We Never Share, Divulge or Display

Names, identity documents and residential addresses are used only in the Respondent Verification Protocol (RVP) .  In absolutely no circumstances are names, identity documents or residential addresses shared with, divulged to or displayed in a manner accessible by any third-party individuals, organizations, Users, Members or Respondents.

As expressly indicated in our General Terms and Conditions, SP.A may be legally compelled to disclose personal information to legal authorities if access to them is material to an investigation, indictment or court case in the event of a commission of an illegal act through the use or access to SP.A’s Services.

Your Choices

Sharing Preferences. You are solely responsible for the social media applications you use and for controlling the account preferences that control the sharing of to our Services. To change whether certain information is publicly viewable, you can adjust the settings in your account.

Marketing Communications. We send you marketing communications consistent with your choices. You can unsubscribe from our promotional emails by adjusting your account settings or via the link provided in the emails. Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Notifications. You can opt-out of receiving notifications for posts, votes, echoes, comments, and followers by adjusting your profile and/or operating system (i.e., iOS or Android) settings.

Third Parties

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this PCAP document does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

For example, any information you share with Google as a consequence of sharing or interacting with YouTube content on Social Pulse Asia is governed by Google’s privacy policy. Google now provides users some control over the collection of data by its users and API Clients like Social Pulse Asia. When in doubt, consult the privacy policy of the entity responsible for facilitating the display of content on our Services, before choosing to interact with it, so you can make an informed decision about your privacy.)

Security

We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, as our Services are hosted electronically, we can make no absolute guarantees as to the security or privacy of your information.

Children

We do not knowingly collect, maintain, or use personal information from children under the legal age of consent in the countries where Social Pulse Asia operates, and no part of our Services is directed to children. If you learn that a child has provided us with personal information in violation of this PCAP document, then you may alert us at surveymaster@socialpulse.asia.

International Transfers of Data

Social Pulse Asia operates primarily in the Asia region. The term “Operates” here means that our Services are intended primarily for Asia users and respondents. Notwithstanding our primary focus on Asia, we intend that we will have visitors from all over the world. Thus it must be noted that our Services use web hosting third party corporations which are hosted in the United States. If you visit our Services or choose to use our Services from the European Union or other regions of the world with laws governing data collection and use that may differ from Philippine laws, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. By providing any information, including personal information, on or to our Services, you consent to such transfer, storage, and processing.

Updating Your Information or Requesting Account Deletion or Posing a Question

You can update your account and profile information through your account settings. You can delete your account at Social Pulse Asia at any time by placing a request to have such an action done. We will have 30 calendar days to act on your request. You can also request to have your status as a Verified Respondent revoked. All personal identifying information (name, identity documents, residential address information) shall be erased from the database record housing your Verified Respondent account. However, all data and information that you submitted in Cognition Surveys or Life Situation Surveys that are not identifiable to you, shall be kept existing in that same database record. The reason for this is that your data and information on surveys are already included in reports, publications and other aggregate summaries and as such cannot be removed without nullifying the integrity of the document. If you have questions about your privacy on the Services or this PCAP document, please contact us at surveymaster@socialpulse.asia.

Primacy of local relevant laws.

All contents of these PCAP document must be compliant with any relevant laws in the countries in which Social Pulse Asia is registered and operating. In the Philippines, the local relevant law is RA 10173 otherwise known as the Data Privacy Act of 2012.

Changes to the Privacy Policy

We will post any adjustments to the PCAP document on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share personal information previously collected from you through our Services, we will notify you through our Services, by email, or other communication.

Contact Information & Effective Date

If you have any questions, comments, or concerns about our activities, please email us at surveymaster@socialpulse.asia.

The effectivity date of this PCAP document is January 1, 2021.