•  Effective Date: 5 October 2023
•  Modified Date: 25 September 2023

This Privacy Policy applies to Full Circle Research (“Full Circle”) and all of Full Circle’s online market research panel communities and market research sample sources including, but not limited to, Survey Roundtable. This Privacy Policy defines how Full Circle collects, stores, uses and discloses your “personal data” or “personal information” or “personally identifiable information” (referred to in this Privacy Policy as “Personal Data” defined below). Full Circle processes Personal Data on its own behalf (for our market research panel communities of which you may be a member) where we are a data controller and for other companies (their market research sample sources of which you may be a member) where we are data processor. Full Circle will, and will cause its affiliates to, establish and maintain business procedures that are consistent with this Privacy Policy.

This Privacy Policy constitutes a binding agreement between you and Full Circle. Your use of our websites or services, or your participation in market research, constitutes your consent to the terms of this Privacy Policy.

We Protect Your Privacy

Full Circle is a leading online market research company. Full Circle is committed to the protection of privacy and security of Personal Data and conforms its privacy and security practices to applicable laws and regulations, including, without limitation, the California Consumer Privacy Act (“CCPA”), the California Privacy Rights Act (“CPRA”) and other applicable U.S. State laws including Virginia, Connecticut, Colorado and Utah, the General Data Protection Regulation (“GDPR”) and UK GDPR. Full Circle strives to conform its privacy and security practices to the codes of standards of applicable market and opinion survey research associations, including, without limitation, the Insights Association (www.insightsassociation.org) and ESOMAR (www.esomar.org).

What Personal Data Does Full Circle Collect and Process?

As used in this Privacy Policy, Personal Data means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with a particular data subject, consumer or household. Personal Data includes information such as real names, postal addresses, email addresses and social security numbers.

Personal Data may also include unique identifiers, IP addresses, biometric information, internet or other network activity (such as browsing history, search history, etc.), geolocation data, audio/visual data and even inferences which may be drawn from any of the above to create a profile about a data subject or consumer.

We may collect Personal Data for the purpose of conducting market research, as expressly stated and agreed to by you, and as otherwise provided in this Privacy Policy. Personal Data collected in connection with market research includes participant names; email addresses; postal addresses; phone numbers; IP addresses; browser fingerprints; device ID; unique identifiers; cookies; geolocation data; web beacons; demographic data, such as age, gender, race/ethnicity, parental status, marital status, postal code, income and education levels; and other information collected through automated means, as described below.

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 Policy and should not include audio, video images or the likeness of anyone other than you.

Full Circle 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, Full Circle may collect and use Personal Data obtained from publicly available sources, such as telephone directories.

Sensitive Information
From time-to-time Full Circle may collect “sensitive personal data” or “sensitive personal information” or “special categories” (referred to in this Privacy Policy as “Sensitive Personal Data”) which, depending on the country in which you live, may include racial or ethnic origin, health records, financial information, union membership, political opinions and religious or philosophical beliefs. If Full Circle collects your Sensitive Personal Data, Full Circle will always obtain your consent.

How is Personal Data Collected and Processed?

We will not make your Personal Data available to any third party without your consent, unless it is for research purposes or required by law, as further specified below.

We may use Personal Data for a variety of reasons, including but not limited to:

Please note that receiving email communications may be a requirement of your participation in our surveys or other research programs. You can opt out from receiving these emails by unsubscribing from the survey or other research program.

Full Circle always ensures that it is permitted to process your Personal Data. Full Circle generally does this by obtaining your consent; however, in limited cases, Full Circle may use a statutory condition to process Personal Data.

If a statutory condition applies allowing Full Circle to process your Personal Data, and you withdraw consent to process your Personal Data, this will not necessarily mean that Full Circle 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 Does Full Circle Collect by Automated Technologies?

As further specified below, we may automatically collect a variety of machine-readable information about you and your device and device capabilities, including the date and time you visited one of our websites the pages you visited, the website you came from, the type of browser you are using (e.g., Firefox, Safari, Chrome, etc.), the type of operating system you are using (e.g., Windows, macOS, etc.), the other applications on device, your Internet Protocol (IP) address, device network provider, device type, time zone, network status, unique device identification number, 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 could be used to uniquely identify your device.

We may also collect the following:

Cookies
Cookies are small text files stored on your computer by a website that assigns a numerical user ID and stores certain information about your online browsing. We may use cookies on our survey site to help us recognize you as a prior user. No Personal Data is stored on any cookie that we use.

We 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 for market research purposes to determine whether you have seen, clicked on or otherwise interacted with an online ad or promotion. We may also select you for a survey or other market research program where cookies may be used for the evaluation of specific advertising or promotions.

If you wish, you can adjust 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; however, doing so may negatively impact your user experience when participating in one of our surveys or other research programs.

Web Beacons
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. A visible graphic image may or may not be associated with the web beacon, and often the image is designed to blend into the background of a web page or email.

We may use web beacons in our email messages to help determine whether our messages are opened and to verify any clicks to links within the email. We may use this information to determine which of our emails are more interesting to users, to improve the quality of the emails that we send, and to query users who do not open our emails as to whether they wish to continue receiving them. The web beacon is deleted when you delete the email.

If you would prefer not to have web beacons in the emails that you receive, you should adjust your email program to receive messages in plain text rather than HTML. It is also possible to detect and control web beacons that are present on web pages by downloading a plug-in for your browser.

Log Files
Full Circle may use logging throughout your survey-taking and research program experiences. When you access any of these services, 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.

Geo-Location Data
Full Circle may collect geo-location information from your computer or device. Full Circle 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. Full Circle will obtain your consent if Full Circle collects or uses your geo-location information.

Digital Fingerprinting
Full Circle may use digital fingerprinting technology, also known as “machine identification” technology (“Digital Fingerprinting”), to gather certain data about you and/or your computer.

This data may include Personal Data, an Internet Protocol (IP) address, as well as other data such as a computer operating system or browser version number. This technology creates a unique computer identifier (“ID”) that may be used to identify and track your participation in a survey or other research program and limit participation.

Full Circle may utilize Digital Fingerprinting technology to assist our clients in ensuring the integrity of survey results by enabling us to authenticate users and to help ensure users participate in surveys no more than the maximum allowable participation. In furtherance of Full Circle’s efforts to assist its clients in protecting and ensuring the integrity of survey results, Full Circle may: (a) link or associate an ID to an individual or to Personal Data of an individual; (b) share an ID with Full Circle’s clients and/or sample or panel providers; and/or (c) receive or obtain a unique identifier that is linked to an identified or identifiable individual. Any unique identifier(s) received or obtained by Full Circle that are linked to an identified or identifiable individual will be protected in accordance with this Privacy Policy.

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, we may, with your consent, collect certain profile information stored in your social media platform account.

Use of Automated Decision Making

If permitted by applicable laws and regulations, we may use automated decision-making to determine the likelihood of fraudulent activity. If our systems determine that your activities associated with you are fraudulent, you may be banned from our services and your profile may be deleted. If you believe that your profile has been wrongfully deleted, please reach us using the contact details in section “Contact Us” at the end of this Privacy Policy.

Automatically collected data may be sent to third-party data processors for the purpose of fraud prevention.

With Whom Does Full Circle Share Personal Data?

Full Circle 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, Full Circle 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 only with your consent.

Full Circle may disclose your Personal Data, profiling data or other research data to third parties as follows:

Full Circle may license certain limited Personal Data to third parties 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.), 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.

Full Circle may maintain Personal Data or machine-identifiable information in order to satisfy your requests and/or Full Circle’s business requirements. For instance, Full Circle may retain the email address of participants who opted out, to ensure Full Circle conforms to any such wish. Any retention of Personal Data is done in compliance with applicable laws and regulations.

Full Circle will only share your personal data with your consent.

Does Full Circle Collect Information from Children?

Full Circle does not knowingly collect Personal Data from children below the age where parental consent is required. If Full Circle becomes aware that Full Circle has inadvertently collected Personal Data from a child below the age where parental consent is required, Full Circle will delete such Personal Data from our database.

Communicating With Members of Our Communities

If you participate in one of our research communities, our invitations to participate in research (and service-related notices) may be sent to you via a variety of electronic methods, including email, social media and SMS. You will be able to select the method(s) of communication you prefer.

What Safeguards Have We Implemented to Help Ensure the Security of Your Personal Data?

Full Circle uses the principles of Privacy by Design and Privacy by Default in the development, maintenance and provision of our Services. We have implemented data protection policies and procedures that govern how we process Personal Data.

The security of your Personal Data is very important to us. We have put in place reasonable physical, electronic and administrative procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your Personal Data.

We cannot guarantee that all communications between us or information stored on our servers will be free from unauthorized access by third parties such as hackers, and your use of our services demonstrates your assumption of this risk.

How Do I Opt Out of Surveys or Other Research Programs?

You may choose whether or not to participate in a particular survey or research program or discontinue your 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.

If you decide not to participate in Survey Roundtable, you can click the Unsubscribe link within any survey invitation or here. Follow the instructions to deactivate your account. You will be removed from all mailings and forfeit all SRT Points that you have earned.

Information for California Residents

The following information applies to residents of California.

Personal Data We Sell or Disclose
CCPA defines the term “sell” broadly. Its meaning includes “renting, releasing, disclosing, disseminating, making available, [and] transferring…for monetary or other valuable consideration.”

Under this definition, and the CCPA’s broad definition of “personal information” (again referred to in this Privacy Policy as “Personal Data”), we may “sell personal information” about you to our clients or other collaboration partners, such as your contact information or certain combinations of anonymized or pseudonymized demographic and other information.

Under the CCPA’s definition, we’ve “sold” the following categories of information to our clients: demographic data, such as age, gender, race/ethnicity; parental status; marital status; postal code; income; and education levels.

We’ve otherwise disclosed the following categories of information, subject to confidentiality restrictions, to our third-party service providers as strictly necessary for them to provide services to us: participant names; email addresses; postal addresses; phone numbers; IP addresses; browser fingerprints; device ID; unique identifiers; cookies; geolocation data; web beacons; demographic data, such as age, gender, race/ethnicity, parental status, marital status, postal code, income and education levels; log files, including Internet Protocol (IP) address, browser type, browser language, the date and time of your request, operating system, referring/exiting pages, and clickstream data; browsing information, such as date and time you visited our website(s), number of pages you viewed, time in seconds you spend on each page, and details of the any website you visited before and/or after participation in one of our surveys or research programs; respondent photos, video, and audio; and social media information (e.g., handles, basic information available on profiles).

When you participate in one of our surveys or research programs, the information you provide or is otherwise collected may be combined with the information of other participants and reported as part of aggregate results. Additionally, the information you provide or is otherwise collected may be used in statistical modeling to better understand trends among the general population. When such statistical modeling is performed, your Personal Data will not be released.

We will not make your Personal Data available to any third party without your consent or required by law, as further specified below.

Notice to California Residents
If you are a California resident, you also have the following special rights, subject to certain exceptions and limitations, that you can exercise as described below:

You have the right to know the categories and specific pieces of Personal Data we have collected about you.

You have the right to know the categories of sources from which the personal information has been collected, the business or commercial purpose for collecting or selling personal information and the categories of third parties with whom we share personal information.

You have the right to request deletion of personal information we’ve collected or maintain.

To exercise these rights, contact us at 877-416-6355 or by filling out the following webform. We may ask you to provide additional information, such as name and email address, in order to verify who is making the request.

Please note that any requested disclosures will only apply to the 12-month period preceding the request, and you are entitled to request disclosure regarding your personal information twice in any 12-month period.

You have the right to opt out of the sale of your personal information. For more information on how to opt out, please click here.

You have the right not to receive discriminatory treatment by Full Circle for the exercise of the privacy rights conferred by the CCPA, including but not limited to, denying you services, charging different prices or rates or providing you with a different level or quality of services.

Please understand, however, that we are in the business of providing market research services to our clients, and any financial incentives we offer to facilitate that goal may be rewarded only if the applicable survey, research project or study is fully and properly completed by the respondent, in the sole discretion of Full Circle.

You have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, please contact us as provided at the end of this Privacy Policy. In order to verify you have authorized an agent, we will require a signed, written authorization from you.

You have the right to have any inaccuracies about your Personal Data corrected.

You have the right to limit the use and disclosure of your Sensitive Personal Information.

If you make a request to access or delete your information, or to opt out of the sale of your personal information, we may ask you for additional information to verify your identity. This information may include your full name, birth date, phone number, email address or other basic personal information about you that we already have on file.

Full Circle may offer opportunities for you to earn money and rewards by completing survey or research programs. Participation in these offerings may require you to provide Personal Data.

For more information about how to opt in to these offerings, or about how to opt out once you have opted in, see the notices and official rules accompanying these incentives.

If you have any questions or want to exercise any of these rights, you may contact us with such a request at FullCirclePrivacy@ilovefullcircle.com or via mail at:

Full Circle Research
11701A Falls Road
Potomac, MD 20854
USA

Information for Virginia, Connecticut, Colorado and Utah Residents

The following information applies to residents of Virginia, Connecticut, Colorado and Utah.

If you are a resident of Virginia, Connecticut, Colorado or Utah, pursuant to your applicable state’s privacy laws and regulations and subject to certain expectations and limitations, you can exercise the rights described below:

You have the right to access your Personal Data.

You have the right to obtain a copy of your Personal Data in a portable and, to the extent technically feasible, a readily usable format.

You have the right to have your Personal Data deleted.

You have the right to have inaccuracies in your Personal Data corrected.

You have the right to opt out of the processing of your Personal Data for specific purposes subject to the applicable law and regulation in your state.

If you have any questions or want to exercise any of these rights, you may contact us with such a request at FullCirclePrivacy@ilovefullcircle.com or via mail at:

Full Circle Research
11701A Falls Road
Potomac, MD 20854
USA

Information for Citizens of the EU, UK and Switzerland About Cross-Border Transfers

Consent for Cross-Border Data Transfers
Your Personal Data may be transferred to recipients in countries other than the country where you are located, including to the United States, where Full Circle is headquartered. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your Personal Data to other countries, we will protect that information as described in this Privacy Policy or as disclosed to you at the time of the collection.

If you are located in the European Economic Area, the United Kingdom or Switzerland, we comply with applicable legal requirements providing adequate safeguards for the transfer of Personal Data to third countries.

Full Circle complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and adheres to the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Full Circle has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of Personal Data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Full Circle adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of Personal Data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Pursuant to the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, EU, UK and Swiss individuals have the right to obtain our confirmation of whether we maintain Personal Data relating to you in the United States. Upon request, we will provide you with access to the Personal Data that we hold about you. You may also correct, amend or delete the Personal Data we hold about you. An individual who seeks access, or who seeks to correct, amend or delete inaccurate data transferred to the United States under EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, should direct their query to FullCirclePrivacy@ilovefullcircle.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice (for Personal Data) or opt-in choice (for Sensitive Personal Data) before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your Personal Data, please submit a written request to FullCirclePrivacy@ilovefullcircle.com.

Full Circle’s accountability for Personal Data that it receives in the United States under the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles and subsequently transfers to a third party is described in the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles. In particular, Full Circle remains responsible and liable under the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles if third-party agents that it engages to process the Personal Data on its behalf do so in a manner inconsistent with the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, unless Full Circle proves that it is not responsible for the event giving rise to the damage.

In compliance with the EU/U.S. DPF and the UK Extension to the EU/U.S. DPF, Full Circle commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU/U.S. DPF and the UK Extension to the EU/U.S. DPF to INSIGHTS ASSOCIATION DATA PRIVACY FRAMEWORK SERVICES PROGAM, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.insightsassociation.org/Resources/Data-Privacy-Framework/Information-for-EU-Swiss-Citizens-to-file-a-complaint for more information or to file a complaint. The services of Insights Association Data Privacy Framework Services Program are provided at no cost to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf

Full Circle is under the enforcement authority of the Federal Trade Commission. Full Circle recognizes that under certain limited conditions, individuals may be able to invoke binding arbitration before the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Panel to be created by the U.S. Department of Commerce and the European Commission.

Full Circle recognizes its potential liability in cases of onward transfer to third parties.

Notice to EU, UK (and Gibraltar) Citizens and Residents
You have the right to review, correct or delete your Personal Data. Specifically:

You have the right to obtain confirmation and information about the processing of your Personal Data.

You have the right to have any inaccuracies about your Personal Data corrected.

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)

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, Full Circle’s access your Personal Data will be limited)

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 at FullCirclePrivacy@ilovefullcircle.com or via mail at:

Full Circle Research
11701A Falls Road
Potomac, MD 20854
USA

Information for Other Citizens and Residents

If you are not a citizen or resident of the EU, the UK, Switzerland or the U.S. States of Virginia, Connecticut, Colorado or Utah, Full Circle commits to resolve complaints about your privacy and our collection or use of your Personal Data. These citizens or residents can address inquiries or complaints regarding this Privacy Policy by contacting Full Circle at FullCirclePrivacy@ilovefullcircle.com or via mail at:

Full Circle Research
11701A Falls Road
Potomac, MD 20854
USA

Links to Third-Party Websites

This Privacy Policy applies solely to surveys and other research programs operated by Full Circle, and not to any other product or service. This website may contain links to a number of third-party websites that we believe may offer useful information. The policies and procedures we described here do not apply to those websites. We recommend 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.

Class Action Waiver

Any arbitration or court trial, related to any claim under this Privacy Policy, whether before a judge or jury or pursuant to judicial reference, will take place on an individual basis, without resort to any form of class or representative action (“Class Action Waiver”). THIS CLASS ACTION WAIVER PRECLUDES ANY PARTY FROM PARTICIPATING IN OR BEING REPRESENTED IN ANY CLASS OR REPRESENTATIVE ACTION REGARDING A CLAIM UNDER THIS POLICY. Regardless of anything else herein, the validity and effect of the Class Action Waiver may be determined only by a court and not by an arbitrator. THIS CLASS ACTION WAIVER IS VOID WHERE LIMITED OR PROHIBITED BY LAW.

Contact Us

If you have questions, comments or suggestions, or if you would like to opt out of our surveys or other research programs, please contact us at FullCirclePrivacy@ilovefullcircle.com or via mail at:

Full Circle Research
11701A Falls Road
Potomac, MD 20854
USA