Vivaldi Partners Inc., together with its subsidiaries Vivaldi GmbH, Vivaldi Partners Limited, and Vivaldi Partners AG (collectively, “VIVALDI”), is committed to protecting the privacy of all information we collect from our clients, research participants and visitors to our corporate and survey websites (the “Website”). This policy applies to all client and personal data that we collect or use in the course of conducting our business, and covers all client information and research participant data housed at any VIVALDI facility or stored on the VIVALDI network.
Information We Collect From or About You
We are in the consulting business which includes market research. Most of the information we collect about you (only a small subset of which may be “personal data” or “personally identifiable information” as defined under applicable law) is information you voluntarily disclose to us in connection with our research studies. Consistent with industry practice, online survey activity is typically conducted on an anonymized basis through the use of randomly assigned identifier codes, so the identity of research participants is not known to us or to the client commissioning the study. Some of our studies take the form of “communities,” which involve repeated interaction over a defined period of time; in those cases, we would typically have personal data about you (including a means to contact you), but other participants in the study would not have access to this information. Data collected as part of our studies may include respondent demographic data and respondent-supplied opinions on products or brands. As to some studies, we may also collect video or audio responses. Research participation is voluntary and participants always have the opportunity to decline involvement or to “opt out” of the research after agreeing to participate, as clearly identified in each survey. If the survey involves an incentive or a contest, we may ask for your name and telephone number or email address to notify you if you are a winner. There is never an obligation to provide this information to participate in the survey but if you don’t provide it, you may not be able to participate in the incentive program. Our legal basis for collection and processing of respondent-supplied personal data is consent; we do not collect personal data without the affirmative consent of the research participant. Consent can be withdrawn at any time.
As to certain studies, we may obtain information about you (which in some cases may be “personal data” or “personally identifiable information” as defined under applicable law) from our clients, third party vendors, or partners for use in connection with the studies. In those cases, our legal basis for the processing of the information is our legitimate interest to perform our obligations under our contract with the client commissioning the research study in question.
If you are a client or work for a client, we likely have collected various contact, business, and in some cases financial information about you in the course of administering our relationship with you or your employer. In those cases, our legal basis for the collection and processing of the information is our legitimate interest to perform our obligations under our contract with you or the company for which you work.
If you choose to use social media (for example, Instagram, Twitter, LinkedIn, or our blog) in order to contact us or find out about our services, we may collect your public-facing profile data, data relating to your interactions with us, and any data you post on message boards which are relevant to our business.
We may collect certain information regarding visitors to our Websites, including IP address, device and browser type, and behavior while on the Websites (e.g., which links were clicked on). We may do so using cookies, which are small files placed on your internet browser when you visit our Websites, in order to offer you a more tailored experience in the future by, for example, understanding and remembering your particular browsing preferences. If you prefer not to receive cookies from our Websites you can disable their use in your browser settings. By doing so you may reduce the functionality of the web pages you view. Currently, our systems do not respond to browser do-not-track signals. Also, when visiting certain of our Websites, you are provided the option to sign up for our newsletter and mailing list, and if you do, we collect the information you supply. If you wish to be removed from VIVALDI’s email list, please email us at firstname.lastname@example.org.
What We Do With Information We Collect
Depending on how we obtain your personal data (as described above), we may either be considered a “controller” or a “processor” under applicable law as to that data. If we are the processor, we will process the data in accordance with the instructions provided to us by the controller of that data.
Regarding data collected as part of our research activities, we collect data in, and in connection with, our studies for research purposes only, and our use of that information is limited to that purpose. Research participant information and answers are not used by any entity as an aid for sales. In many cases, this information (which is typically anonymized) is shared with the client commissioning the study pursuant to our contract with that client. In some cases we may need to share personal data with third parties for ancillary services in support of a research project. In these cases, we require the third party to follow all of the same privacy protection regulations as followed by VIVALDI.
As to client data we collect, we do not use the information for any purpose other than to fulfill our obligations to clients. We keep client information secure at all times, and prevent the use and disclosure of it by our employees or any third parties.
Dispute Resolution & Contact Information
In compliance with the Privacy Shield Principles, VIVALDI commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact VIVALDI at: email@example.com
Within the scope of this privacy notice, if a privacy complaint or dispute cannot be resolved through Vivaldi Partners Inc.’s internal processes, Vivaldi Partners Inc. has agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure. Subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe under the Privacy Shield Dispute Resolution Procedure, please submit the required information to VeraSafe here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/
VIVALDI commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.
We do not rent, sell or give personal data to any third party for the purpose of directly marketing any products or services. Under certain circumstances, we may be required to release personal data in response to a legal request from public authorities including to meet national security or law enforcement requirements. In all cases, VIVALDI will take reasonable steps to ensure the personal data is accurate, complete, current and relevant and being used only for the intended purposes. We will not process personal data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the individual.
In compliance with Privacy Shield’s Notice Principle, VIVALDI informs individuals of the possibility, under certain conditions, for them to invoke binding arbitration, and of VIVALDI’s liability in cases of onward transfers to third party.
Retention of Personal Data
We keep personal data for no longer than necessary for the purposes for which the personal data is collected or processed. The length of time we retain personal data for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
We maintain physical, electronic and procedural security measures to help safeguard client and personal data which are consistent with industry standards and practice and in compliance with applicable law. Third parties that provide us with support or services and that may also receive client or personal data are required by us to maintain security measures similar to ours with respect to such information. We will take reasonable precaution, consistent with industry standards and practice, to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
VIVALDI will subject all personal information received via the Privacy Shield to the EU-U.S. and Swiss-U.S. Privacy Shield Principles. VIVALDI is subject to the investigative and enforcement authority of the Federal Trade Commission (FTC). VIVALDI may be required to disclose personal information in response to lawful requests by public authorities. VIVALDI has potential liability for onward transfers to third parties. Additionally, an individual may be allowed to invoke binding arbitration to resolve disputes under certain limited conditions.
VIVALDI will also collect Employment Information for employees and contractors that it hires.
Your Rights As to Your Personal Data
You have the right to request the following as to any personal data we have about you: that we provide access to any personal data we hold about you; that we update any of your personal data which is out of date or incorrect; where our basis for processing your personal data is consent, that your consent to further processing be withdrawn; where we received your personal data from a third party, inquire where the data originated; that we delete any personal data which we are holding about you; restrict the way that we process your personal data; prevent the processing of your personal data for direct-marketing purposes; that we provide, or not provide, your personal data to a third party provider of services; that we provide you with a copy of any personal data which we hold about you; or that we consider any valid objections which you have to our use of your personal data. Under applicable law, certain personal data may be exempt from such requests in certain circumstances. If you would like further information about these rights or would like to exercise any of them, please email us at firstname.lastname@example.org.
Any personal data which may be collected in the Careers sections of our Websites will be used solely for purposes of the consideration of possible employment. This information will not be used towards research and is not human resources data within the context of the working relationship.
We operate in compliance with the Children’s Online Privacy Protection Act (“COPPA”), governed by the US Federal Trade Commission (“FTC”). We do not collect, use or disclose information from children under the age of 13 online without a statement of permission from a parent or guardian. For more information on COPPA, please visit http://www.ftc.gov/ogc/coppa1.htm.
Compliance and Enforcement