Privacy Policy

Last Updated: 29th September 2017

dunnhumby Limited (dunnhumby, we, us or our) is committed to protecting your privacy and ensuring that your personal data is protected. This privacy policy outlines the type of personal data we collect about you, how we use that data and how we protect it. This policy also explains what to do if you do not want your personal data to be collected by us when you visit our sites, and how you can change data that you have already given to us.

The data controller of the sites is dunnhumby Limited, a data controller is responsible for determining why your data is collected and how it is processed. Our address is 184 Shepherds Bush Road, London W6 7NL, telephone number is 020 8832 9222 and company number is 02388853. dunnhumby’s Data Protection Officer can be contacted at: legal.queries@dunnhumby.com. This Privacy Policy applies to personal data collected about you by us via the sites and your participation in Shopper Thoughts. dunnhumby is part of a larger group of companies so by “group” we mean dunnhumby Limited, its subsidiaries and their own subsidiary undertakings, including our joint venture companies. References in this Privacy Policy to our "sites" include the Shopper Thoughts website and any Shopper Thoughts applications.

THIRD PARTY SITES

If you access the sites via a third party website, we encourage you to read their individual privacy policies and any terms and conditions to understand how they apply to any data you might permit them to share with us. Where our sites contain hyperlinks to third party websites you leave our site when you click through the hyperlinks. We do not control these third party websites or any of the content they contain and we encourage you to read their privacy policies. We do not accept responsibility or liability in relation to your use of any third party site that you access from our sites, or which you use to access ours. You use such sites at your own risk.

1. WHAT PERSONAL DATA DO WE COLLECT?

In this Privacy Policy your "personal data" means information or pieces of information that could allow you to be personally identified. This can include information such as your name, street address, username, email address and telephone number but can also include other information such as shopping habits, preferences and information about your health and lifestyle such as your hobbies and interests.

Throughout the sites you will be asked to provide personal data so that you can register as a member of the Shopper Thoughts community, or if you choose to fill out surveys or participate in prize draws, submit content to the public or community areas of the site, make a comment or enquiry, or for other activities associated with being a member.

When you provide us with personal data and provide your consent, where necessary, any time while you are a member of Shopper Thoughts, you are authorising us to use that data in accordance with the terms of this Privacy Policy, which includes your right to limit or withdraw your consent for our use of the personal data (see "Your rights and who to contact"). We may collect and process special categories of data such as information about your health or photographs you give us, but we will only ever ask for your consent before we do this. If you do provide us with this information voluntarily and we haven’t asked for this information, you agree that we, our group companies and the third party supplier who helps us operate the Shopper Thoughts panel, ResearchBods, may use and store this in our systems until you ask us to delete this from our systems. With the exception of your special categories of data (such as details about your health and any photographs you provide) for which we will obtain your consent, we will process your personal data on the basis that your personal data is required for us to provide Shopper Thoughts services to you under the Terms and Conditions. Please note that we require your personal data in order to register you as a member of Shopper Thoughts and for you to continue being a member of Shopper Thoughts, therefore if you choose to withdraw your consent for us to use this personal data, you may no longer be a member of Shopper Thoughts.

Types of information we collect from you directly as a member of Shopper Thoughts

The types of information you may give us directly include:

• name;
• street address, post code or county;
• email address;
• username;
• home telephone number or mobile number;
• age;
• date of birth;
• household income;
• family composition (i.e. details on children, if any);
• photographs;
• gender;
• results of online surveys relating to issues such as personality, values, attitudes, interests, and lifestyle;
• details of your health such as your physical reactions to the use of certain products; and
• other information relating to your opinions, attitudes and interests (e.g. whether you agree or disagree with certain value statements or behaviours).

Types of information we collect when you visit our sites and/or use our app:

We use cookies and other tools (such as web analytic tools, pixel tags and web beacons) to collect information about you when you visit our sites. For more information about the cookies we use, please click here.

Here are examples of the types of information we may collect from you when you visit the sites:

• information about the type of browser and operating system you use;
• details of the web pages and advertisements you have viewed and the other apps you use on your mobile device;
• your IP address;
• log on time;
• your physical location via geolocation techniques;
• your mobile device category and operating system;
• the hyperlinks you have clicked;
• the times you started and ended your participation in a specific survey;
• details from social networking sites (where you have linked your social networking site to your Shopper Thoughts account); and
• the websites you visited before arriving at our site.

Types of information we collect from other sources.

We may obtain or receive personal data about you from other sources, which could include commercially available sources, such as public databases and data aggregators. Below is a list of the types of personal data that we may collect from such sources:

• name;
• street address;
• age;
• your shopping habits;
• online user activity;
• preferences and information about your lifestyle such as your hobbies and interests; and
• publicly available information such as user-generated content, blogs and postings.

2. HOW WE USE YOUR INFORMATION

Collecting your personal data helps us to better understand what you need from us. By providing your personal data, we can learn more about what types of products and services you might be most interested in and to improve your experience of Shopper Thoughts. We will hold your personal data for as long as you remain a member of Shopper Thoughts, or until you withdraw your consent for us to process your personal data, whichever is earlier (see "Your rights and who to contact").

We may use personal data that we collect about you for the following legitimate purposes:

• register you as a member;
• select you for Shopper Thoughts surveys that you are most likely to enjoy and to notify you about new Shopper Thoughts surveys and specific Shopper Thoughts survey directives;
• with your consent, send you products or samples as part of a Shopper Thoughts survey or help our clients to do so;
• analyse the effectiveness of Shopper Thoughts surveys;
• perform any automated decision making such as:

o performing regional profiling by your postal code;
o analysing trends in your responses or allocate you to a specific customer group in order to understand your shopping habits and what products or services may be of interest to you;
o analyse your participation in surveys to understand you better as a customer and Shopper Thoughts member; or
o process your location or which other apps you use to help our client provide better services to you.

• respond to your queries or comments;
• better understand what products or services may be of interest to you; and
• carry out prize draws or competitions that you have entered.

We may also use personal data that we collect about you for the following additional purposes:

• improve and evaluate our sites, your experience as a member, and our offerings to our clients; and
• track where our users may be coming from and what type of software they are using so we can continuously improve our users' online experience and improve the sites.

3. HOW WE MAY CONTACT YOU

We use an opt-in standard for sending you phone and text messages, which means we will only do so with your express consent. If you elect to opt-out of receiving text messages, we will send you a final message to confirm your opt-out. We will not send you any marketing emails without obtaining your consent. We use an opt-out standard for emails, so please click “unsubscribe” in any emails you receive from us if you wish to opt out of receiving emails from us. We will contact you by email to notify you of any surveys you may wish to participate in, customer service queries, or service or reminder notices. Please note that if you opt-out of receiving our emails, you will not be able to be a member of the Shopper Thoughts panel and we will treat you as having end your membership with Shopper Thoughts. We may also send you notifications via the Shopper Thoughts app to notify you of any surveys that you may wish to participate in.

4. COMMUNITY MESSAGE BOARD

We operate a community message board for the users of Shopper Thoughts. As a member, you are welcome to provide us with a profile picture. Please note that if you do so, you agree to us processing the profile picture and storing it on our systems while you remain a member of Shopper Thoughts or until you tell us that you no longer wish us to hold this. Please be aware that any personal data you submit as content to the sites may become publicly available and used by us or our clients.

FOCUS GROUPS

As a member of the Shopper Thoughts panel, we may invite you to join focus groups that we run from time to time to collect your thoughts on specific products or services. We may contact you via your chosen method of contact to see if you're interested in taking part in the focus group.

RETENTION OF YOUR DATA

We will keep the data we hold about you for 12 months following the end of your membership of Shopper Thoughts or after our client has indicated that that they no longer require your thoughts about a specific product/service, whichever is later, unless you tell us you would like us to stop holding your data.

5. WHAT IF YOU ACCESS FACEBOOK, INSTAGRAM OR TWITTER THROUGH OUR SITES?

As part of being able to provide you with a direct link to Facebook, Instagram and Twitter (and any other social networking applications we may add), we will also be collecting personal data when you connect to these social networking applications via our sites for the same purposes and duration set out in the section called “How we use your information” above. Remember, your privacy settings on social network applications may determine what information we can collect. If you are at all concerned about your privacy in the context of any social network applications, please refer to the privacy policies applicable to those websites which are found here:

Facebook Privacy Policy: https://en-gb.facebook.com/policy.php

Twitter Privacy Policy: https://twitter.com/en/privacy

Instagram Privacy Policy: http://instagram.com/legal/privacy/

Click here to see what types of information we may collect from social network applications.

If you would like more information about the different ways in which we use your information, please click here.

Below is a list of the type of data we may collect from social network applications:

• your name;
• your user ID;
• your e-mail address;
• your gender;
• your birthday;
• your current city;
• your profile picture;
• your URL;
• your “likes”; and
• any content you post via the social networking application.

6. SHARING INFORMATION

The information we collect is used to prepare reports for our retailer and consumer packaged goods clients about surveys run on their behalf. and will not contain your personal data unless you specifically opt-in to us sharing additional data with our clients while you are a member of Shopper Thoughts.

You understand and acknowledge that even after removal, copies of submitted content may remain viewable if other users have copies or stored your submitted content.

We may share your personal data with third parties as described below:

• other companies that form part of the dunnhumby group so that they can understand which products and services are more likely to be suited to you;
• third parties who directly support the running of Shopper Thoughts and other dunnhumby group programmes (including, without limitation, cloud hosting service providers), such as ResearchBods Online Limited and Google Cloud Platform;
• third party agencies who assist us in setting up focus groups to collect your thoughts about products and services you be interested in;
• when you participate in a survey, our retailer or consumer packaged goods clients or fulfilment partners such as Research Bods Online Limited or third party voucher companies so they can deliver product samples or other survey collateral to you;
• our benefits provider, Voucher Express (www.voucherexpress.co.uk) in order to fulfil any rewards due to you as a result of surveys or prize draws;
• when you join a survey and you opt-in for us to share additional data with our retailer or consumer packaged goods client(s) to help them provide you with products, services and advertisements that are more likely to be suited to you; and
• if at any time in the future we (or our assets) are purchased by another company we can share your data with them as one of those assets as new operator of Shopper Thoughts.

Any such clients or third parties are not authorised by us to use your personal data in any other way and will be required by us to implement measures to protect your personal data.

Please note that we may need to disclose your personal data if we are required to do so by law.

INTERNATIONAL TRANSFER OF INFORMATION

You acknowledge and consent that your personal data may be sent to a location which may not afford the same legal protections to personal information as the country in which you live such as our Indian sister company whose employees help us maintain our databases. We will take all necessary measures which shall include adherence to the EU Commission’s standard data protection contractual clauses (http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm) and ensuring we undertake appropriate information security due diligence to ensure that your personal data has adequate legal protections in place at all times.

SECURITY

We take reasonable precautions to keep your personal data secure and where we share your data with third parties we require them to do the same. Access to your personal data is restricted to prevent unauthorised access, modification or misuse and is only permitted among our staff on a need-to-know basis.

INVITATIONS

If you choose to tell someone about our website through tools provided on the site, we will ask you for information needed to send the invitation, such as that person’s email address. We will send the invitee an email in your name inviting him or her to visit the site, and may send follow-on reminders. We will not store the invitee’s email address anywhere in our systems.

UPDATES

If we change this Privacy Policy, we will notify you by posting the updated version of the privacy policy here and contacting you via the channels that you permitted us to contact you (such as email or text message).

YOUR RIGHTS AND OUR CONTACT INFORMATION

We collect and process your personal data without your consent on the basis that your personal data is required for us to provide Shopper Thoughts services to you under the Terms and Conditions for the legitimate purposes set out in this Privacy Policy. See here for a list of the personal data we will collect about you. You will always have the right to stop us from using your personal data (see below) but please note that we require your personal data in order to register you as a member of Shopper Thoughts and for you to continue being a member of Shopper Thoughts, therefore if you choose to withdraw your consent for us to use this personal data, you may no longer be a member of Shopper Thoughts.

We may collect and use special categories of data such as information about your health or your photographs that you give us – but only if we have your consent to do so for the purposes above. If you're unhappy with our use of this type of data, you have the right to stop us from using it as below.

Please note that as a member of Shopper Thoughts, you always have the right to request that we:

- provide you information about how we use your data;
- give you access to, and a copy of your personal data we hold in our systems;
- stop contacting you;
- correct, update or delete your personal data in our records;
- stop using, and ensure that all third parties stop using, some or all of your personal data; or
- note any violations of the privacy policy.

The fastest way to change how we deal with your personal data is to log on and simply click on "My Preferences". You can either opt-out of the consents you have previously given us on the “My Preferences” page or you can send an email to team@shopperthoughts.com.

Please do not hesitate to contact us if you have any questions, comments or concerns about this privacy policy. To assist us in dealing with your request, please provide your full name and details of your query.

In addition, you have the right to lodge a complaint with the Information Commissioner’s Office at https://ico.org.uk/concerns/ about our use of your personal data.