TGM is established in the United Arab Emirates and the information in this Privacy Notice is based on the European Union General Data Protection Regulation (2016/679) or GDPR, which provides a high standard with respect to the protection of Personal Data. However, depending on where you live, other privacy laws and regulations may apply as well. This Privacy Notice applies to residents of every country worldwide.
TGM will, and will cause its affiliates to, establish and maintain business procedures that are consistent with this Privacy Notice.
WHO IS TGM?
TGM provides a global online and mobile research and insights platform that connects Panel Owners to market researchers, brands and Panel Members and research Participants for the sharing of consumer opinions and data. TGM is headquartered in Ras Al Khaimah, United Arab Emirates, with offices in Poland and Vietnam.
Individuals participate in market research on the TGM platform either via membership in our panel, in a panel of one of our Panel Owners or via one of our Partners who direct Participants to a survey or other market research program. Panel Members and Participants participate in surveys or other market research programs for the opportunity to receive and redeem rewards and incentives for their participation.
TGM’s Panel Owners and Partners who direct participants to surveys or other market research programs are Data Controllers who determine the purposes and means for processing Person Data. TGM will only process your Personal Data acting as a Data Processor, at the request of a Data Controller.
Your Personal Data may be used for a number of purposes that are explained below along with examples of categories of Personal information for each purpose. Specific details on the use of Personal information might also be described further within a survey or other market research program. If you would like more information you are always welcome to contact us as described in the “CONTACT US” section below.
TGM PROTECTS YOUR PRIVACY
Registration and participation in our panel or a panel owned by one of our Panel Owners is subject to TGM’s Terms and Conditions. You can find TGM’s Terms and Conditions here.
Your participation in a survey or other market research program is completely voluntary and TGM’s use of your Personal Data is carried out with your consent. Surveys and other market research programs administered by TGM’s Clients, Partners or other third parties and the data collected in connection with those surveys and other market research programs are not subject to this Privacy Notice.
TGM is committed to the protection of the privacy of Personal Data. TGM strives to conform its privacy practices to applicable laws, codes, and regulations, and the codes of standards of applicable market and opinion survey research associations, including, without limitation ESOMAR (www.esomar.org) and the Insights Association (www.insightsassociation.org).
HOW IS YOUR PERSONAL DATA COLLECTED?
Your Personal Data will always be collected by fair and lawful means, for specific purposes. For example, TGM may collect your Personal Data when you register for or participate in our panel, a panel of one of our Panel Owners, complete a survey, participate in another market research program or via automated means or other methods as described in the “WHAT INFORMATION IS COLLECTED BY AUTOMATED TECHNOLOGIES?” section below.
TGM only collects Personal Data for market research purposes.
WHAT PERSONAL DATA IS COLLECTED AND PROCESSED?
The Personal Data that is processed may include your name, address, telephone number, e-mail address, date of birth, and other similar information. TGM may collect Personal Data directly from you when you voluntarily provide it to TGM or TGM may obtain Personal Data from our Panel Owners, Clients or market research firms who have obtained a Participant’s consent. For Panel Members of a panel of one our Panel Owners, TGM will collect data in accordance with their instructions.
TGM may also obtain Personal Data from database owners who have assured us that their databases comprise only individuals who have consented to be included and have their Personal Data shared. Finally, TGM may collect and use Personal Data obtained from publicly available sources, such as telephone directories.
From time to time TGM may collect Sensitive Personal Data which depending on the country in which you live may include, racial or ethnic origin, health records, financial information, political opinions and religious or philosophical beliefs. If TGM collect your Sensitive Personal Data, TGM will always obtain your explicit consent.
You may also submit, upload or transmit content or material, including photos, videos, and/or any other similar or related content or material which may include your Personal Data, for example, when participating in surveys or other market research programs. Such Personal data may be used and disclosed as described in this Privacy Notice and should not include audio, video, images, or the likeness of anyone other than you.
HOW IS PERSONAL DATA COLLECTED AND PROCESSED?
TGM may collect and process your Personal Data for a variety of reasons, including:
- enable your participation in our Panel;
- enable your participation in a panel of one of our Panel Owners;
- gather profiling information about you so TGM can better target specific surveys and other market research programs to you;
- contact you to invite you to participate in surveys or other market research programs;
- update our records of your Personal Data;
- manage our incentives programs and fulfill your requests for such incentives;
- allow you to participate in sweepstakes (if permitted);
- to respond to any messages or requests you may send to us;
- validate your profiling information or answers you provided to a survey or other market research program;
- provide service and support to you;
- detect and prevent violation of our Terms & Conditions;
- to investigate suspected fraudulent activity or violation of another party’s rights;
- to respond to duly authorized information requests of governmental authorities or where required by law;
- in connection with the sale, assignment, or other transfer of our business, in which case TGM will make commercially reasonable efforts to ensure that any such buyer agrees to treat Personal Data in accordance with this Privacy Notice; or
- as otherwise authorized by you.
Please note that receiving email or sms communications may be a requirement of your participation in our surveys or other market research programs. You can opt out from receiving these emails and sms by unsubscribing from surveys or other market research programs.
TGM always ensures that it is permitted to process your Personal Data. TGM generally does this by obtaining your consent, however in limited cases, TGM may use a statutory condition to process Personal Data.
If a statutory condition applies allowing TGM to process your Personal Data and you withdraw consent to process your Personal Data this will not necessarily mean that TGM will cease to process your Personal Data as it may, for example, be under a statutory duty to continue to process your Personal Data for some purposes, e.g. to keep copies of commercial transactions for a minimum of seven years.
WHAT INFORMATION IS COLLECTED BY AUTOMATED TECHNOLOGIES?
TGM may collect certain information automatically. Depending on the country in which you live, such information may be considered Personal Data. Such information includes, but is not limited to information about your device and device capabilities including, but without limitation, the device operating system, the other applications on your device, cookie information, IP address, device network provider, device type, time zone, network status, browser type, browser identifier, unique device identification number (such as Identifiers for analytics or advertising), network provider user ID (a number uniquely allocated to you by your network provider), Media Access Control (MAC) address, mobile advertising identifier, location and other information that alone or in combination may be used to uniquely identify your device. Specific technology is specified below:
A cookie is simply a small text file containing information about the user that is placed by a website on a user’s computer or device. TGM places cookies on your computer or device for survey and other market research program control and fraud prevention purposes.
TGM may also use tracking cookies, tags, and scripts to track certain information about you based on your activity on our site or third party sites. TGM may use this information to determine whether you have seen, clicked on, or otherwise interacted with an online ad or promotion that TGM is working on to help evaluate for one of our research Clients. Subject to your consent, TGM may also select you for a survey or other market research program where cookies will be used to expose you to specific advertising or promotions before the survey or other market research program activity for the evaluation of such specific advertising or promotions.
With your consent, TGM’s Clients or Partners may also place cookies on your computer or device and use those cookies, tags and scripts to track certain information about your activity on certain websites. TGM’s Clients or Partners may use this information for various market research activities.
If you wish, you can choose not to consent to cookies or choose not to accept cookies by adjusting your web browser’s privacy settings to delete cookies upon exiting websites or when you close your browser. You may also configure your browser to block cookies. Not providing consent, deleting cookies or blocking cookies may exclude you from participating in surveys or other market research programs or negatively impact your user experience. For information on how to opt-out of cookies please refer to the section titled ”HOW DO I OPT-OUT?”
Mobile Advertising Identifiers:
A mobile advertising identifier is a string of numbers and letters that identifies an individual smartphone or tablet. On iOS, a mobile advertising identifier is called the “Identity For Advertisers” (IDFA, or IFA for short). On Android, the mobile advertising identifier is the GPS ADID (or Google Play Services ID for Android). TGM may collect mobile advertising identifiers or obtain them from a Partner. TGM may use mobile advertising identifiers in our market research programs or to share your data with Clients or Partners. Subject to your consent, TGM may also select you for a survey or other market research program where mobile advertising identifiers will be used to expose you to specific advertising or promotions before the survey or other market research program activity for the evaluation of such specific advertising or promotions.
TGM will only collect or obtain mobile advertising identifiers with your consent.
A web beacon (also known as a tag, clear gif or 1×1 pixel) consists of a small string of code that is embedded within a web page or email. They may or may not be a visible graphic image associated with the web beacon, and often the image is designed to blend into the background of a web page or email.
TGM may use web beacons in our email messages to help determine whether our messages are opened and to verify any clicks through to links within the email or in advertising or website research to determine if a Participant has viewed ads or other online content that TGM is measuring. TGM and our authorized agents may link Personal Data to web beacons for operational and research purposes.
TGM may collect geo-location information from your computer or device. TGM may use your geo-location data for fraud prevention or for market research purposes, including but not limited to advertising research or other tracking-based market research activities. TGM will obtain your consent if TGM collects or uses your geo-location information.
TGM may use digital fingerprinting technology to gather certain data about you and/or your computer or device. This data may include Personal Data such as an IP address, as well as non-Personal Data such as a computer operating system or browser version number. This technology creates a unique computer identifier that may be used for fraud prevention or to identify and track your participation in a survey or other market research program and limit participation in accordance with the requirements of a specific survey or other market research program.
Social Media Information:
You may also be offered the opportunity to participate in surveys and other market research programs through or with social media platforms. If you choose to participate in surveys or other market research programs through or with social media platforms, TGM may, with your consent, collect certain profile information stored in your social media platform account.
TGM automatically gathers and stores certain information during survey and other market research program participation. Our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol (IP) address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser. This information is periodically deleted as part of normal maintenance routines.
Information TGM Collects from Third Parties:
TGM may obtain Personal Data, behavioral and/or demographic information from third parties, including, without limitation, data management platforms, ad networks, information service bureaus, other market research suppliers and/or social media platforms. TGM may use the Personal Data, behavioral and/or demographic data received from these third parties for various purposes, including, but without limitation, data validation, data append, development of marketing insights, fraud detection purposes.
WITH WHO DOES TGM SHARE PERSONAL DATA?
TGM will not make your Personal Data available to any third party without your consent, unless it is required by law, as further specified below.
If a survey or other market research program or other activity includes making Personal Data available to a third party, TGM will only share your Personal Data with your consent. If data collected is used for statistical modeling to better understand trends and preferences amongst specific groups or audiences within the general population, only limited Personal Data shared will be used only for market research purposes and again only with your consent.
TGM may disclose your Personal Data, profiling data, or other research data to third parties as follows:
- in connection with market research services (including our incentives programs), to our agents, contractors or Partners that facilitate such services; provided, however, such parties are restricted from using your Personal Data in any way other than to provide services to TGM;
- with agents, contractors or Partners of TGM in connection with services that these individuals or entities perform for, or with, TGM. These agents, contractors or Partners are restricted from using this information in any way other than to provide services for TGM. TGM may, for example, provide Personal Data to agents, contractors or Partners for hosting our survey websites, for data collection or processing services, or for sending you information that you requested, but those parties cannot use your Personal Data for their own purposes unrelated to the work they are doing for us;
- with Clients of TGM, but in these cases your Personal Data will only be shared with Clients:
- i) with your consent, or ii) for permitted research purposes in accordance with the codes of the Insights Association and ESOMAR.
- in connection with the request or requirement of any lawful request by public authorities, to meet national security or law enforcement requirements;
- pursuant to required legal process, to the related compelling party;
- when TGM believes that disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with suspected or actual illegal activity;
- In connection with the sale, assignment, or other transfer of TGM, in which case TGM will require any such buyer to agree to treat Personal Data in accordance with this Privacy Notice. In the event that a sale, assignment, or other transfer of TGM is not consummated with a prospective buyer, TGM will require the third party not to use or disclose your Personal Data in any manner whatsoever and to completely erase the same; or
- as otherwise authorized by you.
- TGM may license certain limited Personal Data to third parties (e.g., data brokers, data aggregators, etc.) for market research purposes, including, but without limitation, the licensing of individual-level and/or aggregated-level data (e.g., product and/or service purchasing or usage activity, website visitation data, internet search history, etc.) for the development of audience insights and/or look-alike models, for the purpose of sale of such data to the third party’s customers for the purpose of performing analytics and providing marketing intelligence. This information may be shared via a cookie (cookie ID), a mobile advertising identifier, an email address or other method. After look-alike modeling or aggregation have been performed, Personal Data is deleted.
Additionally, identifying information and information collected by automated means may be provided to third parties, including, without limitation, Clients, Partners, agents and/or vendors for the purposes of identifying respondents for re-contact surveys or communications, fraud detection and/or prevention, database matching, data validation, data append, coding, data segmentation, and reward, incentive, and/or sweepstakes or promotion related services.
TGM may maintain Personal Data or machine identifiable information in order to satisfy your requests and/or TGM’s business requirements. For instance, TGM may retain the email address of Participants who opted out to ensure TGM conform to any such wish. Any retention of Personal Data is done in compliance with applicable laws and regulations.
Again, TGM will only share your personal data with your consent.
DOES TGM COLLECT INFORMATION FROM CHILDREN?
TGM does not knowingly collect Personal Data from children below the age where parental consent is required. If TGM becomes aware that TGM has inadvertently collected Personal Data from a child below the age where parental consent is required, TGM will delete such Personal Data from our database.
WHAT SAFEGUARDS HAS TGM IMPLEMENTED TO HELP ENSURE THE SECURITY OF YOUR PERSONAL DATA?
The security of your Personal Data is very important to us. Accordingly, TGM has put in place reasonable technical, physical, and administrative safeguards to protect the information TGM collects. Only those employees who need access to your information in order to perform their duties are authorized to have access to your Personal Data.
Despite the safeguards TGM implements, transmissions over the Internet and/or a mobile network are not totally secure and TGM does not guarantee the security of online transmissions. TGM is not responsible for any errors by individuals in submitting Personal Data to TGM.
RETENTION OF PERSONAL DATA
TGM will store Personal Data no longer than necessary for the purpose of the processing activity or as authorized by you. This period may also be based on TGM’s or one of our Panel Owner’s or Partner’s contractual commitments to you, applicable periods of limitation (to bring claims) or according to applicable law.
You have the right to review, correct, or delete your Personal Data, subject to applicable laws and regulations. Specifically:
- Right of access — You have the right to obtain confirmation and information about the processing of your Personal Data
- Right to rectification — You have the right to have any inaccuracies about your Personal Data corrected
- Right to erasure — You have the right to have your Personal Data deleted (this right is limited to data which according to law and regulation may only be processed with your consent, if you withdraw your consent for processing)
- Right to restriction of data processing — You have the right to require that the processing of your Personal Data be restricted (during the course of any investigation into honoring your request, TGM’s access your Personal Data will be limited)
- Right to data portability — You have the right to have your Personal Data transferred to another party (this right is limited to data provided by you)
If you want to exercise any of your rights, you may contact us with such a request using the contact details provided in the “CONTACT US” section below.
Upon receiving a request from an individual, TGM will attempt to provide the requested information within 30 days, providing that the request is such that it can be reasonably be responded to in that time frame. If more time is required, TGM will notify you within thirty days.
In certain situations, however, TGM may not be able to provide access to some Personal Data. This may occur when:
- providing access to Personal Data would be likely to reveal Personal Data about a third party;
- disclosing the information would reveal confidential commercial information; or
- the information has been collected for the purposes of a legal investigation.
If TGM denies an individual’s request for access to their Personal Data, TGM will advise the individual of the reason for the refusal.
HOW DO I OPT-OUT?
Your decision to participate in a survey or other market research program, respond to any specific survey question or provide Personal Data, including Sensitive Personal Data, will always be respected.
You may choose whether or not to participate in a particular survey or other market research program, refuse to answer certain questions or discontinue participation at any time. However, failure to provide certain information or fully participate in a particular survey may preclude you from receiving incentive compensation or participation in future certain research studies. For more information about incentives, please refer to TGM’s Terms and Conditions by clicking here.
Panel Members of a panel of one of our Panel Owners that no longer want to participate in surveys, other market research programs or be subject to the use of automated technologies or other activities, including cookies, can opt-out by visiting the Privacy Settings page of the member portal for the panel you belong. The Privacy Settings page can also be reached by clicking on the opt-out links on survey invitations. Finally, Panel Members and Participants can contact us by using the contact details provided in the “CONTACT US” section below.
TGM stores data in the European Union (EU) and the European Economic Area (EEA). However as a global organization, a TGM affiliated company or non-affiliated service provider may collect, process, store or transfer your Personal Data outside your originating country.
The (EU) and the European Economic Area (EEA):
TGM’s legal entities outside the EU and EEA have entered into intra-company data protection agreements using standard contractual clauses prepared by the European Commission. TGM has contracts in place with service providers and other business providers that require the contracting parties to respect the confidentiality of your Personal Data and to handle European Personal Data in accordance with applicable European data protection laws.
In accordance with data protection laws of the Russian Federation, TGM collects, processes and stores Personal Data of citizens of the Russian Federation in the Russian Federation and only subsequently transfers that data to the EU or the EEA.
LINKS TO THIRD PARTY WEBSITES
This Privacy Notice applies solely to our surveys and other market research programs, and not to any other product or service. Our surveys or other market research programs may contain links to a number of third party websites that TGM believes may offer useful information. The policies and procedures TGM describes here do not apply to those websites. TGM recommends that you carefully read the privacy notices or policies of each site that you visit for information on their privacy, security, data collection and distribution policies. By participating in any of our surveys or other market research programs or any of our websites following any Privacy Notice change, you freely and specifically give us your consent to collect, use, transfer and disclose your Personal Information in the manner specified in such then-current Privacy Notice.
TGM very much values your opinion and feedback. If you want to review, correct, or delete your Personal Data or have questions, comments or suggestions, or if you would like to opt-out of our surveys or other market research programs or have questions about your Personal Data, please contact us:
Or via postal mail at:
TGM Research FZE
8th floor, Business Center 4
Al Nakheel, Ras Al Khaimah
United Arab Emirates
ATTENTION: Privacy Compliance Officer