Overall privacy

Commitment

Toluna USA Inc. ("Toluna" or "we" or "us") is an online data collection company focused on providing high quality data to the full-service marketing research industry, advertising agencies and consultancies. We build and maintain large online consumer panels. You can be assured your privacy and the confidentiality of your information is our number one priority. All of the data that Toluna collects in our research studies report as aggregate information, that is, information about groups - not individuals. Individual information is never reviewed or published without your consent, as it is irrelevant to the research conducted by our clients. All individual information provided is held confidential in accordance with the terms of this Privacy Policy.

Toluna complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Toluna has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to Toluna's certification, please visit http://www.export.gov/safeharbor.

The information we gather

Toluna gathers personal information when an individual registers to become a member of our panels. Your participation in any of our panels and surveys is voluntary. After registration we ask panel members to provide us with more personal information so that we may invite them to appropriate surveys. To become a Voice of the Modern Traveler Community member, we ask that you fill out a registration survey that gathers some personal and general consumer information. We ask for your email address so that we can send you email invitations to participate in our upcoming surveys and subject to the preferences you expressed when registering, to send you newsletters to make you aware of new features or contests running on the site. The other information we gather, such as your name, address, gender, birthday and employment status is for matching you with the appropriate marketing research projects. Your birthday is used to automatically update your age for us to target age-related marketing groups. We ask you for this information as a means to see if you might qualify for particular projects. All email contact from Voice of the Modern Traveler Community will be sent to your primary email address that you gave to us upon registration. If you become a Voice of the Modern Traveler Community member, your information (name, address, city, state, and zip) is also used for the purposes of incentive fulfillment. When incentive points are deposited in your account and you wish to redeem them or you are determined as the winner of physical gift card in a sweepstakes, this information is required so that we may send your reward to the appropriate recipient address. From time to time, a third party may be used for issuing checks or processing the delivery of rewards; your personal information will not be used for any other reason, but to mail you your reward.

In some circumstances, Toluna may ask you to inform us of your sensitive personal data, unless we are permitted to process such sensitive personal data by law, we will ask for your consent. In general sensitive data that may be collected by Toluna may cover: your racial or ethnic origin; your political opinions; your physical or mental health or condition; and your sexual life. This information is not shared with any third party, except as required by law and as part of a transfer of Toluna's business.

You should be aware that any personal information you choose to make public on the site, in the Community area (as an opinion or topic in a message board or live chat or any other public area or forum) can be read, collected, or used by other users and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit or make public. In addition, we are not responsible for the content you publicly post on the site that can be found via web-based search engines. To request removal of your personal information from our blog or community forum, contact us at help@voiceofthemoderntravelplanner.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at help@voiceofthemoderntravelplanner.com.

Use of this information

Toluna does not sell or transfer the personal information collected about the members of its panels or the individuals that take surveys for us. Information which is personally identifiable will only be transferred with your prior permission on a case by case basis, except for the narrow exceptions specified below. If you are a member of the Voice of the Modern Traveler Community, your information is stored in our proprietary database so we may call upon it to determine which people match up with specific research studies. If we think your profile makes you a potential candidate for a study, we will email you an invitation to make you aware of this opportunity. From time to time Toluna may use third-party software for email list management and email distribution, or may use third party list management providers to match the members of our Panel to members of other lists or panels, or to validate accuracy of personal information you provide. We may use third parties to provide us with data they have collected about you, and append this data to your demographic profile. In such cases only a minimum amount of information is transferred to these third parties so as to enable them to perform specific functions on our behalf. We also may share your information with our service providers, such as to provide prizes you have won or other incentives for your participation in our panels.

Your information may be transferred to other countries, including the United States. All such transfers shall solely be made in accordance with applicable law.

Sharing

Though we make every effort to preserve your privacy, we may need to disclose your personal information when we have a good-faith belief that such action is necessary to comply with a judicial proceeding or a court order or if we believe it is necessary in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Toluna site terms, or as otherwise required by law. Toluna may also disclose your personal information to third parties where it has your express permission to do so, or where it can reasonably be inferred from the circumstances that you consent to the disclosure to the third parties.

The Use of Cookies and Local Shared Objects on Our Site

Cookies:

One or more "cookies" will be placed on the hard disk of the computer(s) used by site visitors, panellists and survey takers in order to allow Toluna to recognize the participant when they connect to the Toluna website, in order to facilitate the management of Toluna, for statistical purposes (pages consulted, date and time of consultations etc.), and to enable us to provide the participant with surveys specifically tailored to his / her interests. This will not affect the performance of your computer but simply provide you with additional opportunities to receive more surveys relevant to your interests.

Only information collected by cookies as specified in this section of our privacy policy is automatically collected from users of the site. In the event that we do collect any personal data about visitors to the site it is available only to Toluna.

By the use of the site all site users authorise cookies to be put in place and their use by Toluna and Toluna's clients and business partners. The cookies will expire after one year.

Site users may disable the installation of "cookies" or to delete cookies installed by Toluna or its clients. To do so you should modify your browser settings click on the help section of your Internet browser and follow the instructions.

Digital Finger Printing:

In general, Digital Fingerprinting technologies assign a unique identifier or "Machine-ID" to a user's computer to identify and track the computer. Toluna will not use Digital Fingerprinting technology (the "technology") to collect personal 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. Toluna will use the technology to assist Toluna's clients in ensuring the integrity of survey results. The technology will analyse 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 will be an alpha-numeric ID. After creating the unique identifier, Toluna does not retain the information ID by the Technology to create the unique identifier. In furtherance of Toluna's efforts to assist its clients in protecting and ensuring the integrity of survey results, Toluna (a) may link or associate your unique identifier to you and any of your Personal Information; (b) may share your unique identifier with Toluna's 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 Toluna. Any unique identifier(s) received or obtained by Toluna and linked to a specific individual will be protected in accordance with this privacy policy.

Toluna shall use commercially reasonable efforts to ensure that the technology is safe, secure and does not cause undue privacy or data security risks.

Toluna shall use and distribute the technology in a professional and ethical manner and in accordance with (a) Toluna's privacy policy, (b) any statements and/or disclosures made by Toluna to respondents, and (c) applicable Laws and Codes.

In the event that Toluna discovers or learns of any unethical conduct in connection with the use of the technology, or that the technology is being used in a manner that is inconsistent with the statements and/or disclosures made by Toluna to respondents or in violation of applicable Laws and Codes, Toluna will take immediate action to prohibit such unethical conduct and to ensure the proper administration of the technology.

Many browsers including Internet Explorer, Firefox, and Google Chrome contain a "do not track" optional setting. In general, when a "do not track" setting is active, the user's browser notifies websites that the user does not want the user's personally identifiable information about an individual consumer's online activities tracked over time and across different Web sites or online services. Websites are not required to honor a do not track request and as required by amendments to the California Shine the Light law, we are informing you that we do not honor such requests.

Access to Your Information; Member Services Area/Update, Correct, Delete Information

You have the right to gain access to your data and correct it. In order to access this data you may either write to the address below or Contact Us at help@voiceofthemoderntravelplanner.com.

We provide you with a Members Area on our site; here you may correct or update your membership information or delete your membership. If you are a panel member and delete your membership, your profile information will be permanently removed, but may be stored in our disaster recovery databases, and in such circumstances will not be used for commercial purposes. Please note that in most cases, it will take two or three business days for your information to be completely removed from our records; but please allow up to fifteen days.

Opt-Out Policy

By becoming a Voice of the Modern Traveler Community member, you agree to receive Emails inviting you to participate in surveys that we feel may match your experiences and background. From time to time, we will also email newsletters to you to make you aware of new features or contests running on our site. You may update your registration information at any time. Please see Correct/Update Policy below.

Correct/Update policy

If you need to correct any of your profile information or if you would like to update any of your information, you may automatically do so by clicking on Your Profile after logging in. By following the appropriate directions, your information should be automatically updated in our database.

Delete/Deactivate policy

 

If you choose to end your membership with Voice of the Modern Traveler Community or to require us to cease processing your personal data, you may automatically discontinue your membership by clicking Unsubscribe in the footer of our Homepage or by contacting us at help@voiceofthemoderntravelplanner.com. By following the appropriate directions, your record will be marked as "unsubscribed", and you will no longer receive communications from Voice of the Modern Traveler Community. In addition, you will forfeit any incentive balance that has not been requested as of the time you opt out. In most cases it will take 2 to 3 days to process this change, but please allow up to two full weeks for your status to be finalised. In the meantime, you may receive emails from us. Email links are provided on the site so that you may contact us directly with any questions or concerns you may have. Each email we receive is read and responded to individually; please allow two to three business days for us to get back to you.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Winners policy and privacy guarantee

Voice of the Modern Traveler Community members are randomly selected to win prizes for participation in surveys, polls, and other promotions. All winners are notified by email of their winnings. For more information, please visit our Terms and Conditions page. Toluna shall post the usernames or first name and first initial of last name of winners on the Reward Page or communicate them via newsletter to all panelists.

Notification of changes

If we decide to change our privacy policy, we will post those changes to this privacy statement, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by Email, or by means of a notice on our home page prior to the change becoming effective.

Security

Toluna takes strict measures to ensure every aspect of your information is kept secure. Access to all personal information is restricted and limited to few key personnel. Our website security is reviewed periodically and can only be accessed via a strict password policy. Toluna will never ask you for private information such as your credit card or social security numbers as a part of our research. We may be required by law to ask for your social security number or other government-issued identifier to comply with reporting laws and regulations if you are the recipient of survey incentives or sweepstakes prize. We use SSL encryption when collecting or transmitting sensitive information. Your profile information is highly confidential and will be used only by Toluna to Email you concerning our studies, newsletters, winner notifications, and incentive redemptions, or as otherwise provided for in this privacy policy.

Social Media Widgets

Voice of the Modern Traveler Community's Web site may include Social Media Features, such as the Facebook Like button (and Widgets, such as the Share this button or interactive mini-programs that run on our site). These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing them.

Single Sign-On

You may be able to log in to our site using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personally identifiable information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this Web site to your profile page to share with others within your network.

Legal disclaimer

We may disclose personal information when required by law or in the good-faith belief that such action is necessary to conform to the edicts of the law or to comply with a legal process served on our website. We may freely assign this Privacy Policy or any of our rights and/or obligations hereunder.

California Privacy Rights

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of information we share with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to the following email address: help@voiceofthemoderntraveler.com. Please allow 30 days for a response.

Children's privacy

Our website is not meant for children, and we will not knowingly collect any information from children under the age of 13 without verified parental consent. We will remove from our files any information of anyone we discover to be under 13 years old/ We are concerned about the safety of children when they use the Internet, and we understand that children may not understand all the provisions of our Privacy Policy or make informed decisions about the choices that are made available to adult users of the Website.

Privacy contact:

Privacy Officer
Toluna USA Inc.
21 River Road
Wilton, Connecticut 06897
USA
E-Mail: help@voiceofthemoderntravelplanner.com