Upwords Privacy Policy

Upwords recognizes the importance of privacy and is committed to maintaining the accuracy, confidentiality, and security of your personal information.

This privacy policy describes our privacy practices, including the personal information we collect, how we manage that information, and the circumstances under which we may disclose that information.

This policy also explains how you can contact us with any questions or requests about your personal information.

As this policy is subject to change from time to time, we encourage you to periodically check our website or contact us at Moderator@upwords.ca or at www.upwords.ca/privacy for updates to this policy.

What is personal information?

Personal information is any information about an individual who can be identified through use of that information alone or along with some other available information.  An individual’s business title or business contact information are not considered “personal information”. For purposes of this privacy policy, “personal information” also excludes information about Upwords’ employees.

Upwords’ collection of personal information

Where possible, we collect your personal information directly from you.

We may collect your contact information from one of our recruiting partners, so we can consider including you in a qualitative research study.  This information might include your name, email address, phone number and mailing address, we well as any details about your habits, preferences and opinions on products or services that you gave our recruiting partner for purposes of arranging your participation in research studies such as ours.  We use this personal information to determine if you qualify to participate in our studies based on criteria provided by our clients and, if so, to invite you to participate.

When we collect personal information from a recruiting partner, we obtain our recruiting partner’s assurances that (a) our use of your personal information, as described above, is consistent with the purpose for which the personal information was collected, (b) you consented to our recruiting partner’s disclosure of your personal information for our use as outlined above, and (c) our recruiting partner’s privacy policy and practices are compliant will applicable privacy laws.

We also collect personal information directly from you, with your express informed consent, when you participate in one our qualitative research activities.  This may include your name, place of residence, household composition, product or service usage information, and your perspectives and opinions on various topics on which our clients have retained us to conduct research.

We may collect this personal information from you in various formats, which vary depending on the particular research project.  These formats may include your typed or written communications, images or pictures you provide us, and video and/or audio recordings of you and your comments.

We may gather this personal information from you during personal meetings with you or through an online platform such as Hatch Tank or Zoom.  We only collect this information from you with your consent.

Where we collect this personal information from a third party online platform, we obtain the assurances of the operator of that platform that: (a) our use of your personal information is consistent with the purpose for which the personal information was collected, (b) you consented to the online platform operator’s disclosure of your personal information for our use as outlined above, and (c) the online platform operator’s  privacy policy and practices are compliant will applicable privacy laws.

How we use personal information

We may use your personal information for the following purposes:

  • To qualify you for participation in qualitative research studies;
  • To contact you to participate in qualitative research studies that you have agreed to participate in;
  • To conduct survey research with you;
  • To send you updates and reminders related to our studies and the use of our online platform; and
  • To prepare analysis and reports for our clients based on the study results.

We never contact research participants about anything unrelated to the studies they agree to participate in.

How we disclose personal information

The data collected from our research studies is shared with our clients in aggregate (or group) form.  We combine the personal information you provide with the information provided by other research participants and we report the aggregate results to our clients in a way that does not identify any of the individual participants.

Your individual personal information may also be disclosed to our clients in the circumstances described below, but only with your express consent.

We sometimes share video recordings of our discussions with project participants with our clients as part of our report to them.  The purpose of this is to highlight specific analysis points of interest and to enable the client to hear directly from project participants in this respect.

Our clients may also:

  • observe our discussions with project participants in person, through webcam interviews or through focus groups;
  • receive the project participants’ profile photos as well as any photos or videos they may have provided to us as part of the study; and
  • receive the personal information that was shared by the project participants during their recruiting interviews, which may include each participant’s name, residential address, household composition, product or service usage information, and their perspectives and opinions on the subject of the research our clients have retained us to conduct.

Whenever we share your personal information with a client, we ensure the client agrees to keep the information confidential and use it only for research purposes.

We may also disclose your personal information where otherwise permitted by law, including where the information is required to be disclosed pursuant to a lawful request by public authorities, judicial or other government subpoenas, warrants, orders or for similar legal or regulatory requirements, or for purposes of the sale or financing of our business.

Your consent

We ensure the purposes for which we use your personal information have been identified to you at the time we collect it and we obtain your consent prior to collecting it.

You may withdraw your consent to our collection, use or disclosure of your personal information at any time by contacting us as directed below.

If you withdraw or do not provide your consent to our collection, use and disclosure of your personal information we may be prevented from offering you the services you have requested.

Cookies

We use “cookies” that identify you as a visitor to our web site.  Cookies help us tailor information to suit your individual preferences. A cookie is a piece of data that a website can send to your browser, which may then store the cookie on your hard drive. The goal is to save you time and provide you with a more meaningful website visit.

By using our website you consent to our use of cookies. Many browsers allow you to disable cookie collection if you wish, or inform you when a cookie is being stored on your hard drive.  If you do not wish to accept cookies please set your browser settings accordingly.

Children

We do not knowingly collect personal information about individuals under the age of consent in their jurisdiction of residence without the consent of their parent or guardian.  If we become aware that we have collected personal information about such an individual without the consent of his or her parent or guardian, we will use reasonable efforts to promptly delete such information from our records.

International Data Transfers

We handle all personal information collected by us in Canada.  However, in working with our clients, your personal information may become accessible in, or transferred to, a foreign jurisdiction. Such information may be provided to law enforcement or national security authorities of that jurisdiction in order to comply with foreign laws.

For Residents of the European Economic Area (“EEA”)

Without limitation to the other provisions of this Privacy Policy, if you are a resident of the EEA you have the following rights under applicable law in relation to our processing of your personal information:

  • The right to access and inspect your personal information or to be provided with a permanent copy of the information being held about you;
  • The right to request the correction of any inaccuracies in your personal information or, where the accuracy of information is disputed, to add additional information to give notice that you dispute the accuracy of the information content;
  • The right to request the erasure of your personal information, particularly where the continued processing of the information is no longer necessary;
  • The right to object to the processing of your personal information, particularly where there are no longer sufficient legitimate grounds for us to continue processing the information;
  • The right to restrict processing, data portability and the right to appeal any automated decision making or profiling; and
  • The right to complain to a Data Protection Regulator about our processing of your personal information.

It is important to note that the rights set out above are not unconditional and the specific circumstances of the processing being undertaken by us will determine if these rights may be exercised.  Further information concerning these rights and their application can be obtained by contacting us as provided below.

If you are a resident of the EEA, our legal basis for collecting and using the personal information described in this privacy policy will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you where the processing is in our legitimate commercial interests which are not overridden by your protection interests or fundamental rights and freedoms.  Typically, our legitimate interests include: improving, providing and enhancing our technology and services, facilitating our security safeguards, conducting commercial research activity and defending legal claims.

 

Where we rely specifically on express consent to collect and process your personal information, you are not obliged to provide your consent and you may subsequently withdraw your consent once it has been provided.  It should be noted however that this may limit your experience with our resources and services.

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us as provided below.

Accuracy of Personal Information

Upwords aims to ensure that the personal information in our possession is accurate, complete and current as required for the purposes for which the information is used.

Safeguarding of Personal Information

At Upwords, we take reasonable measures to ensure the personal information we collect is kept safe from loss, theft, or unauthorized access, use, copying, disclosure or modification.  These measures include physical, organizational and technical safeguards.  We train our staff on privacy best practices and ensure they appreciate the importance of safeguarding your personal information.

Retention of Personal Information

Upwords keeps personal information only as long as it is required for the reasons it was collected or that you subsequently consent to. The length of time we retain information varies, depending on the program, service or event and the nature of the information. The retention period may extend beyond your relationship with us. When your personal information is no longer required, the information is either physically destroyed or deleted in a secure manner.

Inquiries and Requests for Access

If you have any questions about this privacy policy, or would like to access your personal information, please contact Moderator@upwords.ca.

Please note that a fee may apply in processing access requests depending on the type and volume of information requested.

 

Privacy Policy as of January 28, 2019

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