Privacy Policy – India

Effective Date 10th July 2015

Scope of Policy

PointsPanel Limited, (“PointsPanel”, “we”, “us” or “our”) takes your privacy seriously.  This Privacy Policy (together with our Terms and Conditions (the “Terms and Conditions”) as set out at www.pointspanel.com, (the “Website”) and any additional terms of use incorporated by reference into the Terms and Conditions, together, our “Terms of Use”)) describes how your personal data is processed by PointsPanel.  Please review this Privacy Policy and our other Terms of Use carefully.  This Privacy Policy applies to information you may provide to us, or which we may collect, or otherwise acquire, in any of the following ways:

  • when you register on and/or use our Website;
  • if you decide to take part in one of our market research studies, (the “Studies”);
  • through your use of any mobile software applications made available to you by PointsPanel, (the “Apps”) on your mobile device, (the “Device”), once you have downloaded or streamed copies of the Apps on to your Device. The Apps are available from links sent from our Website upon completion of the registration process if you use an iOS mobile Device, or from the relevant platform in accordance with your Device’s operating system, (the “App Site”);
  • when responding to one of our e-diary and online studies, or online or e-mail surveys or questionnaires, which involve collection through your Device of your demographic, product and lifestyle data and data regarding multimedia usage;
  • your use of our Website;
  • when using one of our products or services, (together, our “Services”); and
  • from various third parties in connection with the Studies, such as panel providers.

 

For the purpose of the Information Technology Act, 2000 (IT Act), read with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011 (Data Privacy Rules) the body corporate collecting your sensitive personal data or information is PointsPanel Limited (trading as PointsPanel), whose registered address at Warren Bruce Court, Warren Bruce Road, Manchester, M17 1LB, United Kingdom.  PointsPanel also processes certain personal information as a data processor on behalf of RealityMine Limited, (“RealityMine”), our parent company, which is based in the UK.

Your Consent

When you register on our Website, download Apps, or respond to diary and survey questions and questionnaires that we may send to you, (“Questions”), you will be asked to indicate that you have read and agree to this Privacy Policy and to give your explicit consent to the collection, use and disclosure of your personal information and sensitive personal information as set out in this Privacy Policy by ticking a box. Please also send us an email at support@pointspanel.com providing your complete name and postal address stating that you have read the Privacy Policy and stating your explicit consent to the collection, use and disclosure of your personal information and sensitive personal information as set out in this Privacy Policy,  If at any time you change your mind and no longer want us to process any of your personal or sensitive personal information, please write to us at support@pointspanel.com.

Information We May Collect From You

We may collect and process a range of both personal and non-personal information about you (below is a non-exhaustive list of the types of data collected):

Information You Give Us

You may provide us with information about you by registering to use and/or filling in forms on the App Site, corresponding with us (e.g. by e-mail), downloading or registering Apps, searching for Apps, participating in Studies, surveys or questionnaires, or reporting problems with Apps or our Website.  We use the information to create consumer profiles which are used as set out below.
Personal Information: – you may provide us with certain personal data including your e-mail address, telephone number (this is optional), birth year, household information (including your address), income and gender.  The Apps will not function unless you provide your e-mail address.  Except as otherwise noted below, we will only collect this information directly from you.

Sensitive Personal Information: – you may also give us certain sensitive personal information, including details of your racial or ethnic origin, political opinions, religious/similar beliefs, trade union membership, health, sex life and criminal records.  Although optional, not providing such data may affect the number of points you can collect, (please see our Terms and Conditions for further details). As noted above, we will obtain your explicit consent to the collection, use and disclosure of your personal information and sensitive personal information as set out in this Privacy Policy.

We aim to collect this sensitive personal information directly from you only (including through completion of surveys through the Apps) and have established certain protocols to avoid the collection of sensitive personal information and other private information, (e.g. credit card and social security numbers and other financial information), by the Apps.  Despite this, certain of your sensitive personal information and private information may, inadvertently, be collected indirectly however, we do not knowingly retain or use any such inadvertently collected data, which will be destroyed or anonymised.

Information We Collect About You and Your Device

We also collect the following types of data through the Apps on your Device.

Information Collected From Third Parties: – we may collect certain data from various third parties, e.g. panel providers, including your e-mail address and address, demographic data  and other profiling data (such as details of your past purchases, brand preferences etc.).

Survey Information: – this includes your responses to Questions (answering is optional, but not doing so may affect the number of points you are eligible for).  We and RealityMine analyse your responses and identify your preferences regarding products and services.  Your responses may include details of, for example, your location, if traveling your reasons and mode of transport, who you were with, the general communication media you were using (e.g. the internet), the types of programming or content you were using (e.g. TV networks for sports or news), what you were doing on the internet (e.g. sending or receiving e-mails), how you were communicating (e.g. texting) and how you felt.

Other Specifically Requested Information: – we may specifically ask you to provide information, (e.g. video, audio or image content).  This may include personally identifiable information, (e.g. in the form of an identifiable image of you).  You are entirely free to decide whether or not to supply this information.

Information Relating to the Redemption of Points: – by using the Apps, you will collect points which can be redeemed as cash or other rewards depending on the Study you are taking part in.  To redeem points you will need to create an account on our Website, which requires you to provide us with an active e-mail address and also the e-mail address linked to your PayPal Account.

Automatically Collected Information: – each time you use the Apps we may automatically collect the following personal and non-personal information (including certain “clickstream data”, generated by you and your Device while surfing the internet and interacting with sites, services and Device functions): Certain personal data and sensitive personal data is also collected by cookies when you visit our Website (see below for further details):

Online Browsing and Log Information: – e.g. details of the sites you visit, the apps you use and the resources you access, including news sites/apps or social networks and your interactions with them.

Information Regarding Your Online Activities: – e.g. details of search terms you use and search results, videos you view, products you shop for online, information you enter into forms, materials you download or upload, advertisements you see, information and content on sites or apps that you visit or use and with which you interact and information and content on protected and secure pages/apps that you access, (e.g. the content of complete/incomplete consumer transactions when you are checking out through a shopping cart).

Device and System Information: – e.g. details of technical information, including the type of Device you use, information about the Device and unique Device identifiers, (e.g. IP address and phone number), the browser that you are running and other applications installed or running.

Content Information: – e.g. details of information stored on your Device such as photos, videos and other digital content and details of calendar appointments including appointment starts and end times.

Mobile Usage Information: – e.g. details regarding your use of the Device on which the Apps are installed, which details are collected and transmitted to us ‘in the background’.  This does not require any further activation on your part.  We call this ‘passive tracking’.  This may include data about:

  • the time and duration of calls you make or receive on your Device, (but not call content);
  • when you send or receive text messages, SMS or MMS, (but not message content);
  • the time e-mails are sent and received on your Device;
  • your location (see below);
  • your internet browsing habits;
  • whether people you call, e-mail or send text, SMS or MMS messages to are already in the “Contacts” section of your Device, (the contact details of such people are scrambled to prevent identification, however);
  • your type of Device, when and for how long you charge it, its battery status and whether it is on, off or in stand-by or ‘Airplane’ mode;
  • which mobile network and wi-fi networks you use and at what times;
  • the volume of data downloaded to your Device, the times it is downloaded and the method of connection used (Wi-Fi or mobile network);
  • your usage of other apps/features on your Device (e.g. the camera, though we do not collect any photos (except as otherwise stated) on your Device), including the identity of the apps and features, when you downloaded them, how often you use them and for how long;
  • matters we can deduce from combining the above information, e.g. what apps you were using just before you searched for particular information using your Device’s internet browser; and
  • installation or removal of services containing a unique application number, or when such a service searches for automatic updates.

Location Information

When you first download the Apps you will be asked if you agree to your location information being disclosed to us.  If you consent, we may collect this information using GPS or other technology to determine the current location of you and your Device on a semi-continuous and passive basis.  You will not be notified each time we collect this information.  To turn off location tracking, please uninstall the Apps (see below for further details) or disable location tracking for the Apps if your operating system allows this.

Cookies

We may automatically collect certain information on our Website and through the Apps using “cookies”, (these are small text files that are saved to your Device using your browser, which allow websites to recognize you and store preferences and other information if you return to the website using the same device and browser).  We use cookies for various purposes, e.g. to distinguish you from other users of the Apps and App Site, to analyse how you use our Website and the Apps and to improve user experience.

Information About Children

Generally, the Apps are not directed at, and we do not knowingly collect information from, children under 18.  If we become aware that a child under 18 has provided us with any personal information in connection with such Apps, we will delete this.

If we decide to direct any Apps at children under 18 we will provide such children with an appropriate separate privacy policy and also obtain appropriate parental consent to the collection of personal and sensitive personal information from such children before permitting them to download and/or use such Apps, or participate in Studies.

Parents with concerns should contact us at support@pointspanel.com.

Use and Sharing of Personal and Sensitive Personal Information

We may use personal and sensitive personal information about you for the purposes described below and share such information with third parties as set out below.

Our Use of Your Personal Information including Sensitive Personal Information: – your personal information including sensitive personal information may be:

  • used by us to conduct Studies on behalf of RealityMine;
  • provided by us to, or processed by us on behalf of, RealityMine in connection with the services that RealityMine provides to its customers, as described below;
  • used by us to provide the services described below that RealityMine provides to its customers on our own behalf;
  • used by us to produce anonymised statistics and research analysis relating to consumer demographics and location behaviour;
  • used by us to establish an account on our Website where you can redeem your accrued points and to pay you related cash amounts into your PayPal account, or provide you with other applicable rewards;
  • used by us to tell you about other matters regarding your use of the Apps or participation in our Studies, (including information regarding App maintenance, upgrades and other service related communications);
  • used by us to notify you of any changes to this Privacy Policy;
  • aggregated with personal information of other research participants, anonymised and shared with our other clients for market research, or published; and
  • anonymised and shared with service providers who help us to manage and operate computer systems and analyse data we obtain.

Personal Information including Sensitive Personal Information Shared With RealityMine: – we disclose your personal and sensitive personal information to RealityMine.  RealityMine aggregates Study participants’ data into consumer segments, (pools of users with common interests/characteristics, e.g. “women between the ages of 28-34 interested in travel websites”) and then anonymises it and shares it with its clients for one or more of the following purposes, (occasionally, RealityMine may also share anonymised non-aggregated results for certain limited purposes):

  • advertising research: – this may also result in content or advertisements that you see as part of one of our Studies being modified or replaced;
  • media use analysis;
  • profile building: – RealityMine may use personal information you provide to us outside of the Apps or anonymous identifiers associated with you (e.g. IP addresses) to obtain additional information about you from other public data sources (e.g. regarding your purchases (online and off-line), household and lifestyle information and broader demographic and personal history details) and combine this with other information to create and enhance profiles that are shared as described in this Privacy Policy;
  • targeted surveys: RealityMine may provide its customers with some or all of your anonymised responses to targeted surveys, including specific answers/quotes);
  • statistics and research analysis: relating to consumer demographics (e.g. age, gender, income, where they live, what they buy etc.) and location behaviour).

Additional Disclosures of Your Personal Information including Sensitive Personal Information: – we may also disclose or transfer your personal information including sensitive personal information to certain third parties, e.g. if we buy, sell or transfer any business or assets, are acquired by a third party, undergo another business transition, or become bankrupt, (we will provide you with notice prior to disclosure in these circumstances); if reasonably necessary to comply with laws, regulations, regulatory obligations, court orders or other legal processes; or to enforce the Terms of Use, or to protect the rights, property or safety of PointsPanel, our customers, or others, (including for fraud prevention and credit risk reduction purposes).

Security and Where We Store Your Personal Information including Sensitive Personal Information

Both PointsPanel and RealityMine store your personal information including sensitive personal information on secure servers in the Republic of Ireland and the United Kingdom, using strict procedures and security features to try to keep your personal information and sensitive personal information secure from loss or unauthorized use or access when it is in our possession or control, including reasonable administrative, physical, technical and organizational measures.  No security measures are 100% impenetrable, however and we cannot guarantee against all potential security breaches, or the security of your data transmitted to our Website.

International Transfers of Your Personal Information including Sensitive Personal Information

Your personal information including sensitive personal information may be transferred and stored outside the European Economic Area, (the “EEA“) by PointsPanel and RealityMine, or processed by staff operating outside the EEA.  By submitting your personal information including sensitive personal information, you agree to this transfer, storing or processing.  We will take all steps reasonably necessary to ensure that your personal information including sensitive personal information is treated securely and in accordance with this Privacy Policy and applicable laws.

Retention of Your Personal Information including Sensitive Personal Information

Your personal information including sensitive personal information is only retained for as long as is necessary to fulfil the purposes for which it is collected, as described above and comply with legal requirements.  Apps may continue to operate and collect your personal information including sensitive personal information from your Device even if you use the “private browsing” or similar setting on your browser.  To completely stop this, please remove the Apps by following the instructions here .  If you remove the Apps we will stop collecting your personal information including sensitive personal information, but will retain personal information including sensitive personal information collected before removal.

How To Access and Correct Your Personal Information

To obtain a copy of personal information including sensitive personal information we hold about you, or to request any corrections to or deletion of it, please e-mail us at support@pointspanel.com or write to the Privacy Officer at the address above

Other Websites and Apps

Our Website may contain links to and from third party websites and may also invite you to download apps owned and operated by third parties.  Such websites and apps and any services accessible through them have their own privacy policies, which you should check before submitting any personal information to them.  We are not responsible or liable for these websites, apps or policies, or for any personal data collected through such websites and apps and will not be acting as a data controller in respect of them.

Privacy Policy Changes

If we wish to use your personal information in a way materially different from that stated in this Privacy Policy, we will notify you via e-mail or the Apps and post a prominent notice on our Website.  Instructions on how to choose whether to allow us to use your personal information in this different manner will be included in the notification).

Contact

Please send questions, comments and requests about this Privacy Policy or use of the Apps to the Privacy Officer at support@pointspanel.com and complaints to the Complaints Manager at complaints@pointspanel.com, or the above address.