•  Effective June 2013
•  Modified June 2015

Full Circle Research Co., LLC (“Full Circle,” “the Company,” “we,” “our,” or “us”), operate the website located at www.ilovefullcircle.com (“the Site”). We know that your privacy is important to you. Therefore, it’s important to us.

Through the Site, we operate Full Circle’s Survey Roundtable, through which we provide surveys that can be taken via electronic notification methods such as, but not limited to, email. We provide sample to organizations that conduct research primarily for marketing or for social science purposes. We’re committed to helping you understand how we manage and protect the information we collect. We take privacy seriously, and have taken many steps to help safeguard the information we collect from you.

This privacy policy (“Privacy Policy”) is provided to inform you of our policies and practices and of the choices you can make about the way your information is collected, used and stored. By using or accessing the Site and participating in Full Circle’s Survey Roundtable, you agree to the collection and use of your information by us in accordance with this Privacy Policy and agree to accept the terms of our Privacy Policy. Please take a moment to review the terms of our Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Site or participate in Full Circle and/or Survey Roundtable.

If you have questions or concerns regarding this policy, you may contact the Privacy Policy Office at Privacy@iLoveFullCircle.com. Thank you for joining us.

Your Full Circle Team

Opt-in to Full Circle’s Survey Roundtable: Community members may sign up for Full Circle’s Survey Roundtable by completing the double opt-in process at our Site or through one of our many partners’ Sites. During the double opt-in process, members are sent a confirmation email following an initial request to subscribe at our Site or one of our partners’ Sites, and all members must affirmatively click an additional link in that confirmation email to confirm their opt-in preference.

The Information We Collect and Use: By information, we mean information about you collected through Full Circle, Survey Roundtable and our Sites, including Personally Identifiable Information (PII) such as your name, phone number, email address, residential or work address and non-personally identifiable information such as certain demographic information, as well as information regarding your hobbies, interests and product ownership and other information you provide to us by registering for Full Circle, Survey Roundtable, participating in our surveys or services or making requests for information about our services. Registration for Full Circle’s Survey Roundtable is not required to view non-member areas of the Site. If you elect to register for Full Circle’s Survey Roundtable, we ask you for information that enables us to provide a Full Circle membership. You will be registering with Full Circle on the form provided and such registration may require you to provide contact information such as your name, email address, residential or work address and certain demographic information. In addition, from time to time, we receive e-mail addresses from one of our partners, who may ask us to contact you to offer you a survey.

We may collect other non-personally identifiable information such as your user name and password (your “Login”), IP address and your website browsing patterns (discussed in further detail below). We use such non-personally identifiable information to serve you better and send you surveys that are most relevant to your interests. We and/or our data partners, where you have given such data partners your consent, may also seek other personally and non-personally identifiable information from you or where such information is otherwise publicly available.

We use third party providers to validate the accuracy of personal information you provide, so that we may offer better statistical sample to our clients.  We use third parties to provide us with data they have collected about you, and append this data to your demographic profile. In these cases, only a minimum amount of information is transferred to these third parties so as to enable them to perform specific security functions on our behalf.

Additionally, in certain circumstances, we offer individuals the ability to participate in our client’s surveys outside of Full Circle and/or Full Circle’s Survey Roundtable. If you are asked to participate in such a survey, we will request limited non-personally identifiable information about you. In some cases, after completion of the initial survey, we may request Personally Identifiable Information (PII) about you in order to provide rewards, to offer you the opportunity to join Full Circle and/or Survey Roundtable or to participate in further surveys.

You may be referred to Full Circle, Survey Roundtable or our surveys by one of our third-party business partners. In the event that we ask such partner to contact you with additional survey opportunities, we may share certain basic personal information that we understand such partner already maintains (such as your e-mail address and gender) as well as certain basic information regarding your Full Circle and/or Survey Roundtable activity (such as the last time you completed a survey).

Any information provided to us will be retained and used solely for the purposes of fulfilling your requests, responding to your questions, offering you opportunities to participate in surveys, performing and carrying out the terms of Full Circle (including fulfilling any rewards), or communicating with you as a member of the Full Circle Survey Roundtable community.

We support the rights of our members by limiting the use of their information for legitimate market research purposes and we make every effort to conform to industry standards created to uphold ethical survey research.

Rights Pertaining to Personally Identifiable Information (PII): Full Circle will not rent, sell, or share Personally Identifiable Information (PII—defined as First and Last name, home address, work address, email address and phone number) with other people or nonaffiliated companies except to provide products or services you’ve requested, or when we have your permission, or under the following circumstances:

a)      We respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;

b)      We believe it is necessary to share information in order to investigate or prevent fraud, or to take action regarding illegal activities, situations involving potential threats to the physical safety of any person, violations of Full Circle’s terms of use, or as otherwise required by law;

c)      We transfer information about you if Full Circle is acquired by or merged with another company. In this event, Full Circle will notify you before information about you is transferred and becomes subject to a different privacy policy;

d)     We may sell or share User non-PII information to other advertisers or businesses whom we believe you may find useful and in order to enhance the service provided to our Users.

Member Profile: To further improve the quality, targeting and relevance of our surveys, you may be asked to provide certain demographic data (like your age, gender, zip code, income) and profile data (like occupation, shopping habits and other areas of interest) as certain surveys may be directed to those participants who meet a particular profile. You will be asked to answer certain questions on forms and pages hosted by us. The information we collect will be used to determine whether you are eligible to participate in the survey and will also be maintained by us to enable us to provide you with more relevant surveys in the future.

Opt Out: Members can unsubscribe from Full Circle’s Survey Roundtable at any time, no questions asked. We know that just because you joined Full Circle a month ago doesn’t mean that you necessarily want to stick with us forever. Every survey invitation we send is coded with a special footer that allows you to remove your name from Full Circle and Survey Roundtable and services automatically by clicking a link provided in the message. In addition, you can discontinue your Full Circle and/or Survey Roundtable membership by emailing us at Privacy@iLoveFull Circle.com.

Upon unsubscribing from Full Circle’s Survey Roundtable, we will deactivate your membership account and you will not receive any further survey invitations (though you may continue to receive some previously prepared survey invitations for a few days following the termination of your membership). We will retain your personal information for an indefinite period of time; however, we will continue to protect such personal information in accordance with this Privacy Policy.

If you would like your personal information deleted from our site, please contact us at privacy@iLoveFullCircle.com. We will respond to your request within 30 days. Please note we will not be able to delete data that has been archived, but we can delete current live information in our database.

Aggregate Information: From time to time, we may collect general, non-personal, statistical information about the use of the Site and the Service, such as how many visitors visit a specific page on the Site, how long they stay on that page, and which hyperlinks, if any, they click. We collect this information from you by passive means through the use of technologies such as IP addresses and cookies, which are discussed in greater detail below. We may also group this information into aggregate visitor data in order to describe the use of the Site and Full Circle to our existing or potential business partners or other third parties, or in response to a government request. However, please be assured that this aggregate data will in no way personally identify you, other list members or any other visitors to the Site.

IP Addresses: We collect IP addresses and/or click-stream data for purposes of system administration and to report aggregate information to our advertisers and sponsors.

An IP address is a number that’s automatically assigned to your computer whenever you’re surfing the web. Web servers, the computers that serve web pages, automatically identify your computer by its IP address. We collect IP addresses for purposes of system administration, to report aggregate information to third parties and to track the use of the Site. When visitors request pages from the Site or click on a link in a mailing sent through Full Circle, our servers log the visitors’ IP addresses. We reserve the right to use IP addresses to identify a visitor or member when it will enhance the users experience or if we feel it is necessary to enforce compliance with the Site’s policies or to protect the Company, the Site, the Site’s visitors, Full Circle, Survey Roundtable, our Internet Service Provider partners and/or the members or others.

Click-stream data is information collected by our computers when you request pages from our Site. Click-stream data may include such information as the page served, the time, the source of the request, the type of browser making the request, the preceding page view and other such non-personal information. When analyzed, these data helps us learn how visitors arrive at the Site, what type of content is most popular, what type of visitors in the aggregate are interested in particular kinds of content and advertising, and the like.

Cookies: Cookies are pieces of information that a website transfers to an individual’s hard drive for record-keeping purposes. We use cookies for a number of purposes:

On Our Sites: Most commonly, we use cookies to make web surfing easier for you by saving your preferences while you’re using our Site. The use of cookies is an industry standard—you’ll find them at most websites. We use cookies on the Site to verify a member’s login status. By showing how and when visitors use the Site, cookies help us see which areas are popular and which are not. Information such as the total number of visitors to the Site and pages viewed is most easily tracked with cookies. We may use the information from cookies to make improvements and updates to the Site and to tailor our services to our visitors’, community members’ and survey participants’ needs.

For Banner Ads: When you visit our Site or take one of our surveys without registering for Full Circle’s Survey Roundtable, we may place cookies on your computer that alerts Internet advertising networks that you have visited one of our Sites or surveys. These cookies, which do not track any personally identifiable information, allow us to ask Internet advertising networks to serve you advertisements with respect to survey opportunities, Full Circle’s Survey Roundtable and our Site.

For Brand Awareness Studies: We may place cookies from a third-party technology provider on your computer that signals when you visit a website that utilizes a supported Internet advertising network. We provide only limited non-personally identifiable information to the third party technology provider, including certain demographic information and a coded user identification number. The signal emitted from the cookie includes solely the coded user identification number and the specific advertisement(s) that you may have viewed. Some of our clients may ask us to send you survey opportunities to determine the effectiveness of their Internet advertising based on the signals sent by the cookie about the advertising you may have viewed.

The cookie that we use to recognize you as a Full Circle Survey Roundtable community member when you return to this Site or visit other Full Circle panel Sites employs a technology called Flash. The information gathered via this cookie may be associated with other Full Circle cookies that you have on your computer and used to supplement the information that we have about you. This cookie does not contain any personally identifiable information. We may also use non-Flash cookies or a small piece of code (sometimes referred to as “1×1 clear pixel,” “Web beacon” or “clear GIF”) to help us gather additional information about your Internet usage, including other websites that you visit. On occasion, we may also use non-Flash cookies to understand your exposure to certain Internet advertisements as you surf the Web. To unsubscribe out of this explicitly, please contact us at Privacy@iLoveFull Circle.com.

Additionally, we may allow our panel recruitment partners to use Web beacons and cookies on our Site’s registration pages solely for payment verification purposes. We have no access to or control over these cookies. This privacy statement covers the use of cookies by Full Circle and members of the Full Circle family of companies only and does not cover the use of cookies by any of our partners.

You can set your browser to reject non-Flash cookies, or delete individual or all non-Flash cookies on your computer by following the browser help file directions. For information about how to delete the Flash cookie, please click here. Setting your browser to reject cookies or deleting cookies, however, may interfere with your using some features of other websites and may impair your ability to participate in activities at our Site.

Our servers log the standard non-personally identifiable information that accompanies Internet transmissions, like the date and time of your visit, browser type and version, IP address, and operating system. We use this information to administer the website, analyze trends, track users’ movements within our Site, and gather broad demographic information for aggregate use. We may associate the personally identifiable information you give us with this information and may supplement it further with information supplied by our cookies or other sources. This helps us to understand you better and how you interact with the Site.

By your use of the Site, Full Circle and/or Survey Roundtable, you authorize cookies to be put in place and their use by us and our clients and business partners consistent with the disclosures above. The cookies expire after one year.

Also, you have the option of disabling the installation of new cookies and deleting existing cookies using your browser preferences. Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or indicate when a cookie is being sent and to accept/reject such cookie(s) individually. However, please be aware that some features of the Site will not function properly or may be slower if you refuse cookies.

Clear Gifs (Web Beacons/Web Bugs): Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly in HTML files and are about the size of the period at the end of this sentence.

When you visit a third-party website with which we have a marketing relationship, or when you visit a website displaying content (including advertisements) of a third party with which we have a marketing relationship, we may assign a randomly generated number and store that information as a browser cookie. The random number stored contains no personal information about you or your computer. We may cause our software to query that cookie and to log the random number along with the time and along with other data supplied to us. The ways in which we use these data are described above in the section entitled “Site Usage Information.”

We may use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications. We may also use them to confirm payment to our third party-partners. If you no longer wish to receive our communications sent by email, you may opt-out of receiving them by following the instructions included in each communication.

Digital Fingerprinting: We may use digital fingerprinting technologies to assign a unique identifier or “Machine-ID” to a user’s computer to identify and track the computer. Full Circle works principally with a third-party provider to deploy this technology (the “Technology”) and does not use it to collect personally identifiable information or track the online activities of the user of a computer, and will not disrupt or interfere with the use or control of a computer or alter, modify or change the settings or functionality of a computer. We use the unique identifier to assist our clients in ensuring the integrity of survey results. The third-party provider analyzes publicly available information and data obtained from the computer’s web browser and from other publicly available data points, including without limitation the technical settings of the computer, the characteristics of the computer, and the computer’s IP Address, to create a unique identifier assigned to the computer. The unique identifier is an alphanumeric ID. After creating the unique identifier, we do not retain the information analyzed by the Technology to create the unique identifier. Additionally, to assist our clients in protecting and ensuring the integrity of survey results, we (a) may link or associate your unique identifier to you and any of your personally identifiable information; (b) may share your unique identifier with our clients and with other sample or panel providers; and (c) may receive or obtain a unique identifier linked to you from a third party, including without limitation a sample or panel provider or a client of Full Circle. Any unique identifier(s) received or obtained by Full Circle and linked to a specific individual will be protected in accordance with this Privacy Policy.

Change of Control/Asset Transfer: As the Company develops, we may buy other businesses or their assets or sell all or parts of our business assets. Customer information is generally one of the business assets involved in such transactions. Thus, in the event that the assets of the Company in whole or in parts are acquired by a third party, customer information, including any visitor information collected through the Site, Full Circle and/or Survey Roundtable, would be one of the transferred assets. In the event of a corporate change in control or sale of all or parts of our business assets our users will be notified and given the opportunity to opt-out of any such transfer of their personally identifiable information to the new corporate entity or asset purchaser.

Legal and Site Compliance: The Company reserves the right to disclose member information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) the Company’s rights or property, other visitors, list members, or anyone else that could be harmed by such activities. The Company also reserves the right to disclose visitor or list member information when we believe in good faith that the law requires it. We may also use personally identifiable information to monitor compliance with the Site’s Terms and Conditions.

Communications from the Site

Survey Electronic Notification: We will send you targeted and relevant surveys by electronic notification (such as, but not limited to, email, SMS, social media, smart phones) as is necessary to fulfill Full Circle to you.

Service Notification: We will send you service-related announcements, which are not promotional in nature, on occasions when it is necessary to do so. For example, if our service is temporarily suspended for maintenance, we may send you electronic notification.

Customer Service: Based upon the information you provide us, we will communicate with you in response to your inquiries, to provide the services you request, to fulfill incentive requests and to manage your account. We may communicate with you by electronic communication.

Refer a Friend Program: The Refer a Friend Program allows you the opportunity to earn additional points by inviting your friends to join Full Circle’s Survey Roundtable. The email addresses you submit to the program are sent a one-time email invitation to register on the Site. The email addresses are stored solely for the purpose of tracking any subsequent registrations on the Site so we may award you additional points you earn as a result of these referrals. The email addresses are not disclosed to any third parties and will not be sent any other emails from Full Circle unless they opt in to receive such mailings at the time of registration. Your friends may contact us at Privacy@iLoveFull Circle.com to request that we remove their information from our database.

Security and Information Protection: The security of your information is our top priority. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it; however, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Firewalls: When we store information that you have provided to us when registering for Full Circle’s Survey Roundtable, that information is protected by security measures that include firewalls (a combination of computer hardware and software that helps keep unauthorized visitors from accessing information within our computer network), intrusion detection systems (a combination of computer hardware and software that helps detect any unauthorized visitors) and other tools such as data encryption and physical security, where appropriate. Unfortunately, no data transmission over the Internet or data repository can be guaranteed to be 100% secure. As a result, while the Company strives to protect your personal information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction or inadvertent disclosure of your personal information.

Links to other Sites: Please be aware that when you are on the Site, or when you receive an email message from us through Full Circle, you could be directed to other sites that are beyond our control. There may be links to other sites from the Site’s pages or from the email message we send to you that take you outside our Site. These other sites may send their own cookies to visitors, collect data or solicit personal information. The privacy policies of these other sites may be significantly different from this Privacy Policy. We are not responsible for the privacy practices of these other sites and cannot guarantee the security of any of your personal information collected there. Note that when you link to a third party site from the Site, you may see pre-populated data fields with your personal information; however, that information is not available to the third party unless you take certain actions on the third party’s site, such as submitting a form.

Single Sign-on: We use single sign-on service(s) that allow you to sign into Full Circle and/or Survey Roundtable using your third-party social networking login credentials such as your Facebook or Twitter accounts. These services allow you to link your existing social network profile to your Full Circle account. Once linked, you will be able to post content on the third-party site from Full Circle and interact with your friends. If you choose to use such a sign-on service, Full Circle may also access certain profile information from your third-party social network profile such as your friends, profile picture, etc.

Privacy Policy for Children: We do not knowingly collect information from children under the age of 13 on the Site or through the Service without permission from a parent or legal guardian. If you are under the age of 13, please do not provide any information to us. If we become aware that we have collected information from a child under the age of 13 without the permission of a parent or legal guardian, we will make commercially reasonable efforts to delete such information from our database.

Changes to this Policy: The terms of this Privacy Policy may change from time to time. We will notify you of any material changes to this Privacy Policy by posting a notice on the homepage of the Site for a reasonable period of time after such changes are made, that this Privacy Policy has been updated, and by changing the “Effective” date at the top of this Privacy Policy. We encourage you to check this page periodically for any changes.

Contacting Us: We are nothing if not a community. If you have comments or questions about our privacy policy, please let us know. You can reach the Full Circle Privacy Office at Privacy@iLoveFullCircle.com.