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Privacy Policy Statement

EFFECTIVE DATE : NOVEMBER 1st, 2024

 

1.0 PRIVACY POLICY STATEMENT

This Privacy Policy (“Privacy Policy”) discloses the Leger Marketing Inc. and its subsidiaries (“Leger”) privacy practices for our survey respondents, panel members, market research study participants and market research consultants.  On a global basis, Leger will, and will cause its affiliates to, establish and maintain business procedures that are consistent with this Privacy Policy.

The purpose of this Privacy Policy is to inform you about the Personal Information (“Personal Information”) we collect about you. It outlines how we collect, use and disclose that information when you participate in one of our surveys or research. This Privacy Policy will also explain you how you can verify the accuracy of your information submitted to and how you may correct that information.

When you participate in our market research surveys and events, your personal privacy will be protected. You can be assured of the following:

  • We will not make your Personal Information available to anyone without your knowledge unless it is for research purposes only or if required by law (as described in this Privacy Policy). This includes the following but not limited to: your name, address, phone number and e-mail address.
  • We will never try to sell you anything and we will never sell your name to anyone. That is not our business. We are not telemarketers or direct marketers. We are market researchers interested only in your opinions.
  • Occasionally, we may re-contact you to validate your responses. We will never misrepresent ourselves or what we are doing.
  • Your decisions about participating in a study, responding to specific questions, or discontinuing participation will be respected without question.

We have developed our Privacy Policy based on industry guidelines and standards, and local, national, and international laws, including the California Consumer Privacy Act of 2018 (CCPA), and requirements, and the privacy practices and methods described in this statement are designed to be compliant with the applicable standards, laws and requirements. In North America, Leger is a member of the Insights Association (in the USA) and the Canadian Research Insights Council (CRIC), in Canada, the professional trade association of survey research companies that sets industry standards to which member companies must adhere, and which also protect your privacy.

We are also demonstrating our commitment to your privacy, by complying with the laws and regulations under applicable privacy laws in Canada, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”).

 

2.0 SCOPE AND APPLICATION

The scope and application of the Privacy Policy are as follows:

  • The Privacy Policy applies to all subsidiaries and parent companies of Leger: Leger Marketing Alberta Inc., The Research Intelligence Group Inc., Leger USA Inc., Cube AI Inc., Leger DGTL Inc., its software application LEO App (LEO) and the Leger Happiness Index (LHI).
  • The Privacy Policy applies to Personal Information collected, used, or disclosed by Leger in the course of commercial activities.
  • The Privacy Policy applies to the management of Personal Information in any form whether video, audio, electronic or written.
  • The Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by Leger:
  1. non-personally identifiable information;
  2. your name, business title, business address and telephone number and fax in your capacity as an employee of an organization;
  3. depending on the jurisdiction, publicly available information (e.g. specified by regulation pursuant to PIPEDA in Canada).
  • The Privacy Policy does not apply to “Privileged Information”. In the case of a situation where a government body or any other person requests Privileged Information, we will consult with our attorney before responding to any request for the said information.
  • This Privacy Policy applies to the collecting and processing of Personal Information that Leger receives from individuals in Canada, the United States as well as individuals who reside in the European Union and Switzerland.

 

3.0 DEFINITION

  • “Collection”: The act of gathering, acquiring, recording, or obtaining Personal Information from any source, including third parties, by any means.
  • “Consent”: Voluntary agreement for the collection, use and disclosure of Personal Information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of Leger. Implied consent is consent that can reasonably be inferred from an individual's action or inaction.
  • “Disclosure”: Making Personal Information available to a third party.
  • “Employee”: An employee of or independent contractor to Leger.
  • “Geolocation”: the process or technique of identifying the geographical location of a person or device by means of digital information processed via the Internet.
  • “Interviewer": An employee of Leger who contacts a member of the public for the purpose of conducting survey research.
  • "LEO": refers to Leger Opinion Panel
  • "LEO App": Leger Application from the Apple Store (iOS) and Google Play (Android)
  • “Panel”: A panel of households or individuals recruited by Leger whose members have agreed to participate in telephone, mail or Internet-Survey research from time to time.
  • “Personal Information”: Information that individually or in combination could identify a specific individual.
  • “Privileged Information”: Information protected by a legally recognized right against disclosure.
  • “Respondent”: A member of the public who provides Personal Information to Leger in the course of a survey conducted by Leger. For example, a respondent is an individual who discloses Personal Information to Leger in the course of quantitative or qualitative marketing or social research.
  • "Survey Research" means telephone surveys, mail surveys, Internet surveys, door to door surveys, ad hoc panels, continuous panels, mall intercepts, business-to-business surveys, focus groups, one-on-one executive interviews, media rating services, mystery shopping, employee surveys, and all other types of survey research.
  • “Third party”: An individual or organization outside of Leger.
  • “Use”: The treatment, handling, and management of Personal Information by and within Leger or by a third party with the knowledge and approval of Leger.

 

4.0 PRIVACY POLICY

4.1 The Personal Information We Collect

Personal Information means any information that can specifically identify you during a survey and/or enrollment process.  This information may include but is not limited to, your first and last name, mailing address, phone number(s), e-mail address and in, certain circumstances, your opinions and individual preferences. This information is used to contact you regarding market research opportunities, as well as to send incentive rewards.

In most research surveys, we also collect demographic and professional information, some of which may be considered sensitive in nature, such as your age, gender, occupation, income range, racial or ethnic origin, household composition, language preference, employment status, etc. We ask these questions to help ensure that the demographic profiles of individuals who kindly participate in our surveys accurately reflect the target population that we are trying to approximate.

When participating in Cube AI tests, with your consent, we may also collect and analyze your activities through Cube AI's technology, including any or all of the following: face recordings, voice recordings, screen/browser content/interactions including mouse movement and clicking, text input, device configurations, and any background audio or video content.

We may also collect sensitive information that may include but is not limited to health-related information (disease, conditions and treatment) or financial information. We will never ask you for sensitive Personal Information that could give rise to economic crimes if it were lost, misused or disclosed to an unauthorized party, such as credit card numbers, social insurance numbers, bank account information, passport numbers or driver’s licence numbers.

Personal Information, however, does not include (i) your name, business title or business address and business telephone number and fax in your capacity as an employee of an organization; and (ii) depending on the jurisdiction, publicly available information. However, if in your capacity as an employee of an organization you participate in one of our surveys, your responses will be treated as Personal Information.

We may collect Personal Information about other members of your household. This information may include but is not limited to the age and gender of the other household members. We use this information to determine if certain surveys are relevant to you based on the composition of your household. Sometimes we use this information to invite other members of your household to participate in our surveys.

We offer you the option of inviting friends, family or even co-workers to join our LEO to participate in surveys or any type of event organized with the panel. After having referred the email address of the person you know, we will send him or her a link to register with the LEO and mention that this invitation comes from you.  

 

4.2 How We Collect Personal Information

We will always collect your Personal Information by fair and lawful means. We collect your Personal Information where we have obtained your consent to do so or as otherwise permitted by law.

We may collect Personal Information directly from you or we may obtain Personal Information from clients or research firms who commission us to provide research services on their behalf.  We may also obtain Personal Information from list providers who have assured us that their lists comprise only individuals who have consented to be listed ("opt-in" lists). Finally, we may collect and use Personal Information obtained from publicly-available sources, such as telephone directories.

With your consent, we may collect Personal Information via the use of Cube AI automated technology to allow our clients to understand how to optimize their advertising through attention and behavior insights.

We may use a third-party agent to host surveys or panel events to collect Personal Information, including email address. That information is delivered to Leger directly. Contractual agreements between Leger and third-party vendors ensure that your Personal Information will not be shared with anyone and will not be used for any other purpose without your consent.

The LEO App obtains the information you provide when you download and register the LEO App.   Registration with us is mandatory in order to be able to use the basic features of the application. When you register with us and use the LEO App, you generally provide (a) your name, email address, age, user name, password and other registration information; (b) transaction-related information, such as when you complete a survey; and (c) information you provide us when you contact us for help.  We may also use the information you provided us to contact your from time to time to provide you with important information, required notices and Leger promotions.

In addition, the application may collect certain information automatically, necessary for the prevention and detection of fraud or the evaluation and improvement of protection and security measures, including, but not limited to, the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the LEO App. 

When you visit the LEO App, following your explicit consent, we may use GPS technology (or other similar technology) to determine your current location in order to determine the city you are located within and display a location map with relevant messages. All data relevant to your Personal Information will be anonymized before it is used for research purposes. If at a later date you wish to turn on or off the location services for the LEO App, you can modify your account settings within the LEO App or (and) modify the location settings of your mobile device.

Leger will give notice when Personal Information is collected or when any collected information is later to be provided to third parties. All notices will explain the need for the information and describe how the information will be used. Personal Information will not be used to directly market any products or services to identifiable persons unless that possibility has been disclosed in advance and the opportunity not to participate has been given.

 

4.3 How We Use Personal Information

We identify the purposes for which we use your Personal Information at the time we collect such information from you and obtain your consent, in any case, prior to such use.

We collect your Personal Information for the following purposes:

  1. To conduct quantitative or qualitative marketing and social research on behalf of our clients who include businesses, non-profit organizations and governmental institutions;
  2. To understand respondent opinions to establish suitability for further quantitative and qualitative marketing and social research;
  3. To meet legal and regulatory requirements.

In this context, we may use your Personal Information for any of the following reasons:

  • To invite you to participate in survey research;
  • To conduct a survey research interview with you;
  • To analyze your facial reactions during certain survey responses through Cube AI's technology and create norms for research purposes;
  • To improve user experience with Cube AI’s systems, understand technical functionality and develop new products or services;
  • Cube AI also processes your eye-movement to display a visual representation to their clients to help understand how consumers are reacting to certain parts of their design. This data is represented to our clients as a moving circle around the screen that is meant to be an AI-generated understanding of where you are looking.
  • To participate in longitudinal studies, where you may contacted again to participate in surveys based on responses provided in previous surveys;
  • To validate answers, you provided in a recent survey we conducted;
  • To manage our incentives programs and fulfill your requests for such incentives.
  • To update and to ensure that our records of your Personal Information are correct;
  • To provide services and support that you have requested;
  • To provide you with general information about Leger and our products and services;
  • To send you important information regarding your participation, changes to our LEO terms and conditions;
  • To verify the integrity of submitted information;
  • To detect and to prevent violation of our Terms & Conditions.
  • As otherwise authorized by you.

Data collected from market and social research studies is shared with our clients in aggregate (or group) form, and responses are not attributed to individuals, in other words we combine your survey responses with the responses of all other survey participants and report aggregate responses. Individual level responses are occasionally used, but never associated with any personal identifying information without your explicit permission, except as otherwise stated herein.

 

4.4 To Whom Personal Information is Disclosed

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

The only exceptions when we may disclose your Personal Information and/or survey responses to third parties are as follows:

  • To a client of Leger who commissioned the survey you participated in, who is contractually bound to keep the Personal Information confidential and use it only for research or statistical purposes (in accordance with the guidelines of the Insights Association, ESOMAR and with CRIC Code of Conduct and Good Practice);
  • To a third party engaged by Leger to perform functions on its behalf (including our incentives programs), such parties are restricted from using your Personal Information in any way other than to provide services to Leger;
  • You consent to sharing your identifying information and individual responses with a third party for a specified purpose;
  • In the rare but possible circumstance that the information is subject to disclosure pursuant to judicial or other government subpoenas, warrants, orders or for similar legal or regulatory requirements, except for Privileged Information.  In that specific case, we will consult with our attorney before responding to any request for the information.
  • When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with suspected or actual illegal activity.
  • Leger may be required to disclose an individual's Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. Leger is liable for appropriate onward transfers of personal data to third parties.
  • If Leger is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

 

4.5 Retention of Personal Information

We retain Personal Information for as long as necessary to fulfill the purpose for which it was collected or as otherwise permitted by law. Once this purpose has been fulfilled, subject to any legal exceptions, we destroy or irrevocably erase or de-identify the Personal Information in a secure manner that protects the privacy of the individual whom the information relates to. You may cancel your membership in a program or otherwise request deletion of your Personal Information. Except in cases where we must retain some of your Personal Information for a reasonable period of time for legal, administrative or compliance purposes, your Personal Information will be destroyed, irrevocably erased or de-identified within 14 days following your request for deletion of your Personal Information.

 

4.6 How and When We Obtain Your Consent

We obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information. You may provide your consent to us either orally or in writing. For example, when you respond to a survey, you provide your consent to allow us to use your Personal Information for the purpose of conducting quantitative and qualitative market and social research and, in certain circumstances, to disclose your Personal Information to our clients. 

When you agree to participate in survey research, and the method of data collection is by telephone or in-person, a Leger interviewer then conducts an interview with you. When the method of data collection is by mail, via our web panel or email invitation, you complete a questionnaire yourself.

From time to time, we may collect, use or disclose your Personal Information based on your consent and as permitted by law. If you provide us with sensitive Personal Information such as health or financial information, we will obtain your express consent for the collection, use and disclosure of such sensitive Personal Information.

When you participate in market research telephone interviews and discussions with Leger, the interview may be recorded, or there may be others on the call for note taking, training, or research evaluation purposes. To protect your privacy, only your first name will be used during discussions. You may decline to participate in interviews that are monitored by others or recorded.

 

4.7 Opting-out of Leger

You are always free to choose whether or not to be contacted by Leger and/or LEO, without discrimination.  You should note that Leger emails and LEO emails are not connected, and your subscriptions are considered separate.

If you opt-in to our website, register for a Leger event or you are in contact with one of our representatives, you will be subscribed to our Leger newsletter.  You can unsubscribe from our emails at the bottom of each email received from Leger.  Alternately, you can contact info@leger360.com to request to be unsubscribed.

As a LEO member, you will receive our e-mail invitations to complete surveys. It is useful to sign on to the LEO portal directly to validate if surveys are available. You will not necessarily receive an e-mail each time a survey is on your online profile. If you decide you no longer wish to participate as a member of LEO, upon receipt of your e-mail invitation, you can reply to it with the word "Unsubscribe" in the body of the reply or, alternatively, you can click on the Unsubscribe link at the bottom of the e-mail and you will no longer receive survey invitations. You can also e-mail our helpdesk at support@legeropinion.com with the word "Unsubscribe" in the title. Of course, if you decide you later wish to participate in the community, you are welcome to reactivate your account at any time. However, we are not able to remove your Personal Information from the lists of third parties with whom your information has been shared with your consent or as permitted by this Privacy Policy. By opting out, we may be unable to provide you with certain services or benefits.

LEO will send activation and reward code by text message (SMS) as well as certain promotional materials. You can cancel the SMS service at any time by texting "STOP" to the short code. After you send the SMS message "STOP" to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to join again, just sign up as you did the first time, and we will start sending SMS messages to you again. If you decide to cancel the SMS service, you will no longer be able to redeem rewards. If you are experiencing issues with the messaging program, you can reply with the keyword HELP for more assistance, or you can get help directly at support@legeropinion.com or 1-833-375-3007.

You can stop all collection of information by the LEO App application easily by uninstalling the application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.  

 

4.8 Access to Personal Information

We will make available to you any specific Personal Information on you in our custody or control, that we have collected, used or disclosed, upon your written request, to the extent required and/or permitted by law. We will make such information available to you in a form that is generally understandable, including explaining any abbreviations or codes.

To request access to Personal Information that we hold about you, we require that you fill out the request form and submit it to the Privacy Officer’s e-mail address or postal address shown below in the Contact section. When we receive an access request from an individual, we will attempt to fulfill the requested information within 30 business days, including requests regarding the Personal Information we have in our possession or control about the individual, what it is being used for, and to whom it has been disclosed, if applicable. Note that, in an effort to prevent fraudulent or unauthorized requests for access, we may request identification for authentication purposes. You may also make a subsequent request to the Privacy Officer to correct any Personal Information that you feel is inaccurate or incomplete. You may also request the deletion of your Personal Information, subject to legal and contractual restrictions; however, please note that deletion of some information may impact our ability to provide you with certain services.

In certain situations, however, we may not be able to give individual access to all of their Personal Information. This may occur when:

  • Providing access to Personal Information would be likely to reveal Personal Information about a third party;
  • Disclosing the information would reveal confidential commercial information;
  • The information has been collected for the purposes of a legal investigation. 

If we deny an individual's request for access to their Personal Information, we will advise the individual of the reason for the refusal.

 

4.9 Accuracy of Personal Information

We make reasonable efforts to keep Personal Information in our possession or control accurate, complete, current and relevant, based on the most recent information available to us. We rely on respondents, such as panel members, to keep certain Personal Information relating to them accurate, complete and current. If you register with us, you have the right, and we encourage you, to view and update your registration information at any time.

To update your information, please log-in to your account page on www.legeropinion.com or send an e-mail to our Panel Support Team at support@legeropinion.com

In your request, please be specific and make clear what action you would like us to take with your Personal Information. We will try to comply with your request as soon as reasonably practicable.

 

4.10 Ensuring Third Party Confidentiality

We ensure that all our affiliates and other third parties which are engaged to perform services on our behalf and are provided with Personal Information are required by contract to observe the intent of this Privacy Policy and practices or are governed by the same Privacy Policy.

 

4.11 Use of Cookies

When you visit our sites, take our surveys or sign on to your LEO account, a banner on the management of cookies will be displayed allowing you to activate or not cookies that are not strictly necessary for the proper functioning of our websites.

Our Cookies Policy explains how we use these cookies. It also explains the types of cookies we use, why we use them and how you can change your cookie preferences.

No Personal Information is stored on the cookies that we use.

These technologies are used for quality assurance purposes in order to offer you a positive user experience.  In fact, cookies allow us to collect information that will facilitate user navigation of our sites and continuously improve their presentation and functionality. Cookies also help us display relevant content for the user according to his or her language, region, pages previously visited on our sites, etc.  

Within the scope of specific surveys for our clients, we may be required to install cookies on your electronic devices to allow our clients to identify you as one of our LEO members when you visit their websites. For this type of campaign, your prior consent will be requested specifically.

You can adjust your Web browser so that it notifies you when you receive a request to install cookies or that it completely rejects cookies. You can delete the files that contain cookies; these files are saved on your Web browser. However, deleting them could prevent you from answering our surveys online.

 

4.12 Collecting Information from Children

Occasionally, we conduct surveys with children under 16 but only with parental or legal guardian consent. Depending on the sensitivity of the survey topic, we may seek parental or legal consent for interviewing children between 16 and 17 years of age. If we become aware that Personal Information from a child under 16 has been collected without the consent of such child’s parent or guardian, we will use all reasonable efforts to delete such information from our database.

 

4.13 Safeguards

The security of your Personal Information is very important to us. We have put in place reasonable physical, administrative, electronic, contractual and technological security procedures to protect your Personal Information we collect so as to prevent any loss, misuse, copying, unauthorized access, disclosure or modification of Personal Information. Only those employees who need access to your Personal Information in order to perform their duties are authorized to have access to your Personal Information.

We prevent electronic intrusion by using firewall technology and we use SSL certificates to ensure the confidentiality of the information collected by our web applications. The employees who are granted access to your Personal Information, including email address, can only access it using secure connections and passwords from within our networks.

 

4.14 Questions or Suggestions

If you are concerned or have any complaints or questions about our use of your Personal Information, please contact our Privacy Officer with the subject line “Privacy” at:

Leger Marketing Inc.

Privacy Officer

700-507, Place d’Armes

Montreal (Québec) H2Y 2W8 Canada

privacyofficer@leger360.com

Phone : (514) 982-2464

Facsimile: (514) 221-4127

 

4.15 Changes to this Privacy Policy

We may update and make changes to this Privacy Policy from time to time, consistent with applicable data protection and privacy laws and principles. If we make any substantial or material changes, we will notify you by email (sent to the e-mail address specified in your LEO account), by means of a notice on our website(s) prior the change becoming effective or by other means that we deem appropriate. We encourage you to periodically review our Privacy Policy for the latest information on our privacy practices.

If you disagree with any change to the Privacy Policy, you may close your account or refrain from using our services, or in some cases, by opting out. Continuing to use our services, including our websites, after we post or communicate a change signifies that you consent to the revised terms of the Privacy Policy.