Privacy Policy

Last updated: December 27, 2016

1. Introduction

Verto Analytics Inc. (“we,” “us”) is a market research company. We are passionate about creating new technologies that match today’s market and customer needs, innovating in the areas of data acquisition and partnerships, and driving new inventions by turning data into value-adding insights that help our customers.

Your privacy is a top priority to you, and to us. This Privacy Policy describes how we collect and use personal data about you and how we protect personal data about you. By registering for the Service and/or using the Site, as these terms have been defined below, you agree to this Privacy Policy, as it may be amended from time to time as provided below, and to the processing of your personal data in accordance with it.

In all of our business practices, we apply the market research principles and practices set forth by the International Chamber of Commerce and ESOMAR which can be found here: www.esomar.org/uploads/public/knowledge-and-standards/codes-and-guidelines/ICCESOMAR_Code_English_.pdf and the standards set forth by CASRO, which can be found here: www.casro.org/?page=TheCASROCode.

2. Definitions

As used in this Privacy Policy, the terms enlisted below have the following meaning:

Personal Data means information that relates to an identified or identifiable natural person (for example, corporations are not natural persons).

Research Application means a piece of software that the User installs voluntarily in his/her device, which sends aggregated research data at predefined intervals to our servers for the purposes of market analysis and research.

Service means a market research service in which the Research Application that is placed on Users’ devices analyses Users’ activities, as described in this Privacy Policy and includes the Site and the Verto Smart Panel.

Site means www.vertoanalytics.comwww.vertosmart.comsmartpanelsuomi.fi and/or smartpanel.io and any applicable sub-domains thereof.

You or User means a user of the Service and/or the Site.

3. The Scope of the Privacy Policy

This Privacy Policy pertains to the Service, which is operated by us in collaboration with our partners, including Verto Analytics Oy. Please be reminded that this Privacy Policy applies to personal data that we process when you use the Service. It does not apply to any links to third parties’ websites, services, material, content or applications, which you may encounter when you use the Service. We encourage you to carefully familiarize yourself with privacy policies applicable to any websites and/or services operated by third parties.

Reference is also made to the Verto Smart Panel Terms of Service, available at www.vertosmart.com/about/terms-service. In the event of any conflict between the Terms of Service and this Privacy Policy, the Terms of Service shall prevail.

4. Opt-In to the Verto Smart Panel

The User’s initial registration to and participation in the Verto Smart Panel shall always be the User’s choice (“Opt-in”), subject to the Verto Smart Panel Terms of Service.

5. Opt-In to Research Application

The User’s initial installation and initial activation of the Research Application shall always be the User’s choice (“Opt-in”). Following initial installation and initial activation of the Research Application, we may automatically update an activated Research Application from time to time.

6. Collection and Use of Personal Data

We may collect personal data from Users in a variety of ways, including through online forms, through the Research Application and other software applications, and other instances where Users are invited to volunteer such data. We also automatically collect information about how Users interact with websites, Internet applications and device features. This information is obtained through analysis of logs generated by Users’ activities and through the utilization of the Research Application. We may also automatically generate information such as internal technical identifiers (“IDs”) which may be considered personal data. Below, we describe the personal data that we collect in more detail.

(i) Data You May Provide to Us or Which We May Generate

We may collect or otherwise generate the following information from our Users that may, in certain circumstances, alone or in connection with other data, constitute personal data:

  • First name and last name;
  • Email address;
  • Address and zip code;
  • Phone number;
  • Nicknames;
  • Unique user identifiers (e.g. panelist ID);
  • Date of birth;
  • Personal income;
  • Household income;
  • Job title;
  • Marital status;
  • Gender;
  • Ethnicity;
  • Education level achieved;
  • Number of children in household;
  • Household size (i.e. number of people in household);
  • Answers to surveys carried out from time to time in and through the Service; and
  • Other demographic data you provide to us, such as the number of smartphones owned.

(ii) Data Collected Automatically

The Service may automatically collect the following information from our Users that may, in certain circumstances, alone or in connection with other data, constitute personal data:

  • Information about the device on which the Service is installed, including certain “log” or “signaling” data, such as the device type and manufacturer, operating system, speed, battery status, any network or chipset level data, device identifiers, user settings (e.g., alarms), personalization, and other performance data, such as signal strength, time, date, and location information;
  • Information about connected devices (e.g., printers, chargers, etc.);
  • Information about data, programs and/or applications (“apps”) loaded or stored on the device or accessed through the device, and how you use those apps;
  • Information about your use of the device, and the data, software, and applications described above including, without limitation, the date and time of such use, the length of each session, and the nature of that use;
  • The URL of any web pages you access using your device(s), including, without limitation, page description, or other information included in the referrer URL by the sites you visit;
  • Information about data you enter in forms and search fields on non-secure pages of web sites you visit and applications you use;
  • Search terms you enter when using your device;
  • Information about advertisements displayed to you on your device(s), including information about your interactions with those ads (clicks, etc.);
  • Information about the date, time, size and/or length of calls and texts sent or received by the device, but not the content of any such communication;
  • Information about the size, but not the content, of e-mails and instant messages, and the type and size of any attachments;
  • Information about Wi-Fi hotspots, network access points, cell tower and/or GPS data automatically detected and passively collected by your device as you go about your daily activities, as well as similar location information collected or transmitted by the device when you use it to access location-based services. You consent to the processing of location data in connection with your use of the Service;
  • Time-stamped and encrypted transactional records for particular purchases (not including any financial account information);
  • Encrypted transactional records with associated geographic coordinates; and
  • Information input by you as part of questionnaires and survey studies deployed through your device.

(iii) Data Received From Third Parties

The Service may occasionally collect or otherwise receive data from third parties such as our service providers that may, in certain circumstances, alone or in connection with other data, constitute personal data.  Such data may include, but is not limited to, log data and other information when you visit websites or locations such as your IP address, browser type, referring URL, operating system, date/time stamps, pages viewed, clicks, ad impressions delivered, conversions, simple keyword tags, and mobile device advertising identifiers,  collected by means of technologies such as cookies, web beacons, Bluetooth beacons, and pixel tags.

7. The Purposes for Which We Use the Data

We use the personal data we collect directly from you for the following purposes:

  • To set up and maintain your registration with the Service;
  • To communicate with you;
  • To prevent and investigate fraud and other misuses;
  • To protect our rights and/or our property;
  • To operate, develop, improve and protect our Service;
  • To manage the Service;
  • To provide features available in the Service;
  • To personalize the Service;
  • To process any transactions between you and us, such as to provide you with rewards for using the Service;
  • For market research;
  • To audit and analyze the Service; and
  • To ensure the technical functionality and security of the Service.

We may use the data collected automatically for the following purposes:

  • To manage the Service;
  • To provide features available in the Service;
  • To personalize the Service;
  • To develop, improve, and protect the Service;
  • For market research;
  • For product development;
  • For advertising, in compliance with applicable laws;
  • To audit and analyze the Service; and
  • To ensure the technical functionality and security of the Service.

We use the personal data we receive from third parties for the following purposes:

  • To develop, improve, and protect the Service;
  • For market research;
  • For product development;
  • For advertising, in compliance with applicable laws;
  • To enrich data processed in and through the Service; and
  • To audit and analyze the Service.

8. How We Disclose Data

We will not disclose personal data without permission (opt-in) from the relevant User unless the disclosure of such information is permitted by this Privacy Policy.

By using the Service, you consent to having the information that is collected from you as a User and as specified in this Privacy Policy disclosed to third parties as set out below.

The personal data collected in the Service may be disclosed in the following manner:

(i) Personal Data that You Provide to Us:

We may disclose personal data you provide to us with the following categories of third parties:

  • To service providers, payment processors and data storage service providers, which enable us to provide the Service to you;
  • To public authorities, such as law enforcement, if we are legally required to so or if we need to protect our rights or the rights of third parties; and
  • To our partner companies and customers; and
  • To our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the Service and their advisors in connection with a corporate merger, consolidation, restructuring, or the sale of substantially all of our stock and/or assets or other corporate reorganization, in accordance with this Privacy Policy.

(ii) Data Collected Automatically:

The data collected automatically in the Service may be disclosed to the following categories of third parties:

  • To service providers, such as data analysis companies;
  • To our collaboration partners and our customers, including, but not limited to advertising technology platforms and market research companies, in compliance with applicable laws and this Privacy Policy;
  • To public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties; and
  • To our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the Service and their advisors in connection with a corporate merger, consolidation, restructuring, or the sale of substantially all of our stock and/or assets or other corporate reorganization, in accordance with this Privacy Policy.

(iii) Data Received from Third Parties:

The data we receive from third parties may be disclosed to the following categories of third parties:

  • To service providers, such as data analysis companies;
  • To our collaboration partners and our customers, including, but not limited to advertising technology platforms and market research companies, in compliance with applicable laws and this Privacy Policy;
  • To public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties; and
  • To our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the Service and their advisors in connection with a corporate merger, consolidation, restructuring, or the sale of substantially all of our stock and/or assets or other corporate reorganization, in accordance with this Privacy Policy.

(iv) Aggregate Data:

Moreover, we may disclose information to third parties in an aggregate format that does not constitute personal data and does not allow the identification of individual Users. In conducting our business, we can use, process, analyze, disclose and commercialize aggregated and summary User data in such form that does not enable identification of individual Users, including disclosing such data to our partner companies and customers. This data is anonymous (meaning that the recipient cannot link your identity to the data points contained therein) and includes, for example, data such as statistics related to User behavior such as device and application usage, data and communication usage and time distribution of Service usage activity.

9. Your Rights

You have the following rights with respect to the personal data we hold about you:

  • The right to know what data we hold about you: You control your data at any time. This means that you have the right to review or modify the PII and Transactional Logs we have on file for you at any time. You can review any and all personal data about you in the Service by logging into the web site associated with the Service and choosing to view your Profile. You can review any and all personal data and your transactional logs at any time upon request by sending an email to support@vertosmart.com. We seek to swiftly respond to your inquiry.
  • The right to have incomplete, incorrect, outdated, or unnecessary personal data corrected, deleted, or updated. If you wish to make use of your rights stated above, or if you have additional questions regarding the correction, deletion, or updating of the personal data we hold about you, please contact us at support@vertosmart.com.
  • The right to opt out of receiving electronic direct marketing communications from us: All electronic direct marketing communications that you may receive from us, such as e-mail messages and SMS-messages, give you an option of not receiving such communications from us in the future. If you have any additional questions about electronic direct marketing received from us, please contact us at  support@vertosmart.com.
  • The right to leave the Service. You can leave the Service at any time. This means that you have the right to cease participating in the Service at any time and for any reason (“Opt-out”). However, if you wish to opt out of the Service, you must inform us of that fact. You can do so at any time by logging into the web site associated with the Service and indicating your intention to resign through the form provided, or by sending an email to optout@vertosmart.com. Should you opt-out of the Service, we will no longer store or process any additional information from you. Within ninety (90) days of your opt-out, if specifically requested through a written letter, we shall delete any and all of personal data about you and transactional logs from our systems.

10. Data Security

We use commercially reasonable physical and technical safeguards to secure data about you. For example, access to personal data is restricted to persons authorized to access the personal data and passwords are changed at regular intervals. Despite these efforts, we cannot guarantee the security of personal data during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of personal data, we cannot guarantee that our security measures will prevent third-parties such as so-called hackers from illegally obtaining access to personal data. We do not warrant or represent that personal data about you will be protected against, loss, misuse, or alteration by third parties.

11. International Transfers of Personal Data

By using the Service, you consent to having the personal data collected from you as a User transferred to our affiliates located in other countries. The laws applicable to the protection of personal data in such countries may be different from those applicable in your home country.

12. Children’s Privacy

You must be at least eighteen (18) years of age to register to and use the Service. We do not under any circumstances intend to collect personal data from children under 13.

13. Amendments to this Privacy Policy

This Privacy Policy may be amended at any time. You can tell when changes have been made to the Privacy Policy by referring to the “Last Updated” legend on top of this page. We encourage you to familiarize yourself with the Privacy Policy regularly for any amendments. If we materially change the ways in which we use and disclose personal data, we will post a notice on the Site. Your continued use of the Service following any changes to this Privacy Policy constitutes your acceptance of any such changes made.

14. Communications from Us

We may from time to time send you either email communications or push notifications to computing devices with an installed copy of the Research Application. Such communications will occur solely in order to communicate with you regarding your use of the Service or any part thereof, to activate the installed Research Application, or to invite you to participate in further research projects including but not limited to additional surveys.

15. Questions or Concerns?

Should you have any questions regarding this Privacy Policy, your privacy as it relates to the use of the Service, or the protection of the personal data we hold about you, please contact our Privacy Administrator via e-mail at privacy@vertoanalytics.com, or by mail at Verto Analytics Inc., 79 Madison Ave, 2nd Floor, New York City, NY 10016, USA. We seek to swiftly resolve any concerns you may have.

Last updated: December 27, 2016

Verto Analytics Inc.
79 Madison Ave
2nd Floor
New York City, NY 10016
United States