Privacy Policy
1. INTRODUCTION
This Privacy Policy applies to all the products, services, websites and apps (collectively referred to as “Services”) offered by Inkblot Holdings, LLC (“Inkblot Holdings). References to "data" in this Privacy Policy will refer to any information collected by our services, whether it be information collected in our research (see, “Research Data Policy”), information collected in a form on our website (see, “Marketing Data Policy”), or information inserted on a website hosted by us (see, “Website Data Policy”). This policy does NOT cover HR data.
In accordance with the Children’s Online Privacy Protection Act we do not knowingly collect or store any Personal Information for children under the age of 13. If you are under 13, please do not provide us any personally identifying information
2. WHAT DATA DO WE COLLECT AND HOW IS SUCH DATA USED?
The following types of information are collected:
· Research Data
· Marketing Data
· Website Data
· Social Media and Platform Data
The definitions of each type of information collected and its uses are found below or by clicking the above relevant hyperlink.
A. Research Data.
(i) Why We Collect Research Data. Inkblot Holdings, LLC is in the business of marketing, market research, and research education/consulting. This means that one of the primary services of Inkblot Holdings is to collect, analyze, and report on data aggregated from consumers. Consequently, any data collected as a part of one of Inkblot Holdings’ studies is for the purpose of the research it has been commissioned to perform by a client (whom are often times major brands/companies).
(ii) Type of Research Data is Collected. All of the research performed by Inkblot Holdings is opinion-based research that focuses on respondents’ self-reported thoughts, feelings, and behaviors. None of the questions will ask you for personally identifying information (“PII”), such as name, address, or phone numbers.
There are two classes of data we will collect in our research:
· Meta-Data – Meta-Data is data that is recorded automatically about the respondent. This includes:
o Date and time the survey was started
o Date and time the survey was completed
o The referring link
o The session ID
The meta-data we collect is done through the use of SurveyGizmo cookies. To find out more about cookies, how they’re used, and what they’re used for, see Section 4 for “Website Data.”
· Self-Reported Data – Self-Reported Data is data that the survey respondent is filling out and willingly submitting to Inkblot Holdings. This can take a few forms, including, but not limited to:
o Text data – Text data is when a respondent needs to write/type in a response manually (as opposed to selecting an answer), like the number of boxes they purchased, how much they spent on a product, or the first thought that comes into their mind when they think about the brand.
o Scale data – Scale data is when we ask respondents to apply a numerical score to the extent they disagree or agree with statements. This can also be referred to as “Likert scale” data.
o Ranking data – For ranking data, we ask respondents to order options from most to least preferred.
o Single-select or multi-select – For single-select or multi-select questions we ask respondents a question and provide them with a number of answers from them to choose from.
The self-reported data we collect uses some form of research method. This can include online surveys (and include the third-party vendor SurveyGizmo), paper surveys, phone-based interviews, ethnographies, or other research means.
(iii) How We Collect Research Data. All of the information we collect via our research is anonymized, aggregated, and analyzed.
By “anonymize” we mean one of two things:
· Automatic Anonymization - We have prevented our surveys from collecting meta-data such as IP Addresses, geo-locations, and invite data.
· Manual Anonymization – In some surveys, respondents will use open ends as an opportunity to include PII or other sensitive information, such as name, address, or phone number. When PII is discovered in the data, we delete it from the CSV version of the data, and purge that record from the survey platform.
In addition to anonymity, your data is also kept confidential. We do not give or sell your actual individual responses to anyone. The only exception is in some projects where the client who has commissioned the work wants a copy of the dataset.
By “aggregate” we mean that often time data is processed and reported on overall or by subgroups rather than reporting on a single case alone. However, there are some exceptions to this rule, such as when data processing requires the identification of outliers or if the goal of the research can be accomplished through the identification of unique cases for inspiration and innovation.
By “analyze” we mean that all of the data is usually analyzed via descriptive, inferential, or other more advanced statistics. These statistics are put in a report and the report is then presented and given to the client who commissioned the research.
(iv) How We Use Research Data. Once the data is anonymized, aggregated, and analyzed, it is used for two purposes:
· A client report
· An Inkblot Holdings project
A “client report” is the end-product of our services to our clients. These are reports that use the results of the data analysis to answer core business problems and marketing challenges.
An “Inkblot Holdings” project is when the company uses data aggregated across client projects to form additional products and services, such as database norms, predictive analytics tools, or other things.
B. Marketing Data
(i) Why We Collect Marketing Data. Inkblot Holdings collects marketing data to better help our customers. By using marketing data we can develop new products and offerings that help us better meet our clients’ needs.
(ii) Type of Marketing Data Collected. There are three types of marketing data that we collect:
· Mailing List Data
· Email Interaction Data
· Contact Page Data
Mailing List Data - On our website there are a number of places where you can sign up for our mailing list. Examples include, but are not limited to:
· The general Mailing List Form
· The Case Study Form
· The White Paper Form
In all of these cases, the form requires that you submit the following information:
· Your first name
· Your last name
· An email
Email Interaction Data - Because our marketing emails are managed through third-party vendors, such as Mailchimp and Hubspot, your interaction with these emails provides additional information that is collected via Mailchimp’s and Hubspot’s cookies or other tracking technology. Data that are collected by both Mailchimp and Hubspot include (but are not limited to):
· Device information – including IP address, operating system, browser type, among other information.
· Usage information – including interaction with the email, such as date, time, page views, clicks, among other information.
Contact Page Data - On the “Contact” page, users can provide their information to contact us. This form requires that you submit the following information:
· Your first name
· Your last name
· An email
· A subject line
· A message
· Whether or not you want to be included in our mailing list
(iii) How We Collect Marketing Data. For “Mailing List Data” and “Contact Page Data”, The above information is collected only if the visitor consents—that is, only if the visitor enters their information and submits it to us. We also use a double opt-in verification on most forms, so that after entering and submitting your information, you then must verify that you want to opt in to the mailing list via email. This insures that we are only contacting those who want to be contacted.
For “Mailing List Data” and “Email Interaction Data” the information is collected via third-party vendors, such as Mailchimp and Hubspot. To better understand the privacy policy of your data stored at Mailchimp, feel free to review their “Privacy Policy for Contacts”. To better understand the privacy policy of your data stored at Hubspot, feel free to review their “Privacy Policy for Everyone”.
Additionally, “Email Interaction Data” collected by Mailchimp and Hubspot is done so through the use of cookies and other tracking technology. This kind of data is closer to our classification of “Website Data” than “Marketing Data.” Scroll down to read our section on “Website Data” to find out more about cookies and tracking technologies.
(iv) How We Use Marketing Data. By using marketing data we can develop new products and offerings that help us better meet our clients’ needs. Submitting this information will add you to our mailing list. This means that from time to time, Inkblot Holdings will send you marketing emails. Certain Marketing Data is emailed directly to the individual in charge of new business development.
C. Website Data
(i) Why We Collect Website Data. We collect website data to optimize our website to your preferences. Such technologies may also be used to analyze:
(ii) Type of Website Data Collected. All users who visit our website have the following information recorded:
· Device Type - We collect whether your visit was done on mobile, desktop, tablet, or other.
· Visitor Source – We collect whether your visit was on Chrome, Safari, or other browsers.
· Operating System – We collect whether your visit was on an Android, iOS, windows, or other operating systems.
· Traffic Source – We collect whether you visited our site directly or whether you were referred to by a search engine, a link from another site, a display ad, or social media links, among others.
· Geography – We collect the city, state, and country from which you visited our website.
· Google Search Words Used – We collect search terms used to get to our site.
· Site Activity – We collect date and time visited, visitor IP address, and the page(s) visited.
· Conversions – We collect whether or not you use certain buttons or forms after seeing one of our advertisements.
(iii) How We Collect Website Data. We capture the Website Data using “Cookies.” Cookies are small pieces of data that websites store on a device or browser to improve the user’s experience. Cookies stay on the users device or browser for a set period of time before expiring. For example, some cookies expire immediately after your session has ended, while other cookies won’t expire for 3 years. This practice is commonly used across all websites, especially commercial websites. All users who visit our website may have the following cookies installed:
· Functional and Required Cookies – These cookies help with core functions on the website. They are required because they allow visitors to navigate effectively and use key features they might otherwise not be able to use.
· Analytics and Performance Cookies – These cookies allow us to better analyze how users interact with our website. This allows us to continually improve and optimize how the website performs.
· Advertising Cookies – These cookies allow us to show our services to potential customers or to track if potential customers took a desired action on our site.
· Web Beacons, Tags and Tracking technologies. These are small strings of code placed on a web page or in an email. Such technologies allow your browsers to recognize and store certain type of information such as previously established cookies, the time and date you viewed a page with a beacon and description of the page.
The cookies we use are from seven different third-party vendors: Surveygizmo, Squarespace, Mailchimp, Google, Hubspot, Facebook, and Linkedin. Specifically, the Google services used include Google Ads, Google Analytics, and Google Search Console.
In most cases you may be able to opt-out of the Cookies. If you delete certain cookies that are needed to operate a site, a site may no longer function.
To see a list of the cookie names, duration, and purpose as explained by Squarespace, visit their page on cookies here.
To see a list of the cookie names and purpose as explained by Google, visit their page on cookies here.
To see a list of the cookie names and purpose as explained by Mailchimp, visit their page on cookies here.
To see a list of the cookie names and purpose as explained by SurveyGizmo, visit their page on cookies here.
To see a list of the cookie names and purpose as explained by Hubspot, visit their page on cookies here.
To see a list of the cookie names and purpose as explained by Facebook, visit their page on cookies here.
To see a list of the cookie names and purpose as explained by LinkedIn, visit their page on cookies here.
Please note that while some of our business partners mentioned above may use cookies on our site, we may have no access to or control over these cookies.
3. WHAT IF I DON’T WANT MY INFORMATION COLLECTED?
A. General. There are two ways to prevent or manage any data that you provide through our site or services:
· Don’t submit your information to our surveys – The easiest way to prevent us from collecting your data is by not giving it to us. You have every right NOT to submit your information to our surveys.
· Delete Your Data – If you submitted to our surveys, you may one day decide you no longer want us to have your data. If this is the case, then contact us to delete your data. See Section 5a for how to exercise this right.
· Don’t submit your information to our forms – The easiest way to prevent us from collecting your data is by not giving it to us. You have every right NOT to submit your information to our forms.
· Unsubscribe – If you submitted to our forms and joined our mailing list, you may one day decide you no longer want our emails. If this is the case, all of our emails have an “unsubscribe” button, which allows you to take yourself off our mailing list.
· Disable Site Traffic Data On Our Website - Inkblot Holdings’ website will prompt you with a pop-up notification at the bottom of the screen when you first arrive on the website. This bar will say: “By hitting ‘OK’ you agree to the use of analytics cookies, which help us better understand site traffic data. For more information, see our privacy policy.” If you do not want Squarespace’s analytics cookies to record site traffic data then do not hit “OK.”
· Clear Cookies In Your Browser – Most devices/browsers allow you to see what cookies are installed. They also provide you with the option to delete all cookies or to delete cookies from a specific website. Resources to help you do this can be found here:
B. California Rights. California law provides California residents with specific rights regarding their personal information. The California Consumer Privacy Act of 2018 (“CCPA”) defines “personal information” as information that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
Your Rights:
· Access/Right to Know. You have the right to request access to: (i) personal information we collected about you, (ii) information regarding the source of that personal information, (iii) the purposes for which we collect it, and (iv) the third parties and service providers with whom we share your information. You may request such access by emailing us at: Privacy@inkblotholdings.com
· Deletion. You have the right to request that we erase data we have collected from you. You can request this deletion request by emailing us at : Privacy@inkblotholdings.com
· Opt-Out of Sale. You have the right to opt-out from us “selling” your personal data as that that term is defined in the California Consumer Privacy Act. A “sale” of personal information is defined broadly: “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.” You can opt-out by emailing us at : Privacy@inkblotholdings.com
C. Nevada Rights. If you are a consumer from the State of Nevada, you may opt-out of the sale of personal information that we process, as defined by Nevada law. To opt-out please email us at: Privacy@inkblotholdings.com, providing your first and last name, email address on file, and state of residence.
5. GENERAL DATA PROTECTION REGULATION (GDPR) AND COMPLIANCE
Inkblot Holdings is headquartered and operates in the United States. In order to perform our contractual obligations with you and other legitimate reasons, such as conducting and managing our business and services, we may process, store, and transfer Personal Information in a country which may be outside of your own, such as the United States. By providing us with your Personal Information you acknowledge such transfer of information out of your jurisdiction. If you do not wish for certain Personal Information to be so transferred, please do not provide your Personal Information to us and/or take steps whether described herein, or otherwise, to prevent the collection of your Personal Information.
We will only use your Personal Information when the law allows us to. Generally, we will not collect or access any Personal Information other than in the manner described above. We always balance any impacts on your rights before we process your information.
A. Your Rights Under GDPR. Individuals have certain rights in regards to the information they provide Inkblot Holdings (and its clients). This includes the right to manage, delete, access, restrict access to or otherwise withdraw consent for use of, the information which you provided to them in your responses. However, please note that some of these rights may be subject to some exceptions or limitations. Rights which individuals are entitled to are:
· Right to access your data. You have a right to check with us to be certain we are lawfully processing your information.
· Right to correct your data. If you believe any personal data we have collected is inaccurate you may request a correction of such information. You must request only truthful, accurate, and complete corrections.
· Right to delete your data. You may also request that we delete the personal Information that we have in our possession about you. If you ask us to delete your information before we have used it for the necessary purposes set out in this policy, we may not be able to do so, due to technical, legal, regulatory and contractual constraints.
· Right to object to processing your data. If you believe that our processing of your personal data for a legitimate interest impacts your fundamental rights, you have the right to object to such processing. You may also object to the use of your Personal information for direct marketing purposes.
· Right to Restrict Processing. You may request restriction of processing of your personal data which will suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (c) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
· Right to Transfer. You have the right to request a transfer of your personal data to you or to a third party. We will provide to you, or a third party you designate, your personal data in a commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
· Right to Withdraw Consent. You may withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.
B. Data Consent. All surveys start with a consent form that requires the user to hit "Yes, I want to participate" (or a similar equivalent) to opt in.
C. Data Retention and Deletion Policy. All surveys data will be kept indefinitely.
D. Data Protection and Security. Wherever appropriate, proper data protection and security means have been put in place to limit access to who can come in contact with the data collected. We employ commercially appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, and to maintain its accuracy and integrity. We implement and maintain commercially appropriate technical, physical, administrative, and organizational measures to ensure a level of security appropriate to the risk for our use of the personal data. For personal data of EU/EEA and UK residents, we also take into account the risk of varying likelihood and severity for the rights and freedoms of individuals.
E. Data Breach Policy. All data breaches will be reported to the proper authorities
6. DATA TRANSFERS AND PRIVACY SHIELD CERTIFICATION:
A. Privacy Shield. Inkblot Holdings complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (Privacy Shield) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom and Switzerland to the United States in reliance on Privacy Shield. Inkblot Holdings has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
B. Third Party Data Transfer Policy. Inkblot Holdings, LLC typically does NOT transfer any data to a third party acting as an agent on its behalf. However, from time-to-time, Inkblot Holdings, LLC reserves the right to do so. In the context of an onward transfer, Inkblot Holdings, LLC has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Inkblot Holdings, LLC shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.
C. Exercising Your Rights. If you wish to exercise any of the above rights with respect to your survey data, please contact our Data Privacy Controller at: Privacy@inkblotholdings.com
D. Complaint Resolution. In compliance with the Privacy Shield Principles, Inkblot Holdings, LLC commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact Inkblot Holdings, LLC at: Privacy@inkblotholdings.com
Inkblot Holdings, LLC has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, INSIGHTS ASSOCIATION PRIVACY SHIELD PROGRAM.
If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.insightsassociation.org/get-support/privacy- shield-program/privacy-shield-eu-swiss-citizens-file-complaint for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain limited conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
E. Jurisdiction on Compliance Matters. The Federal Trade Commission has jurisdiction over Inkblot Holdings’ compliance with the Privacy Shield.
F. Responses to Law Enforcement Agencies or Legal Claims. Inkblot Holdings, LLC may be required to disclose personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
7. CONTACT FOR QUESTIONS.
IF YOU FEEL THAT WE ARE NOT ABIDING BY THIS PRIVACY POLICY, YOU SHOULD CONTACT US IMMEDIATELY VIA TELEPHONE AT 603-319-4977 OR VIA EMAIL at: privacy@inkblotholdings.com
Email: privacy@inkblotholdings.com
Phone: 603-319-4977 (between 9:00am and 5:30pm EST)
Mail: Inkblot Holdings, 9 Sherwood Road, Windham, NH 03087, Attention Privacy Manager
Updates to Personal Information: If you would like to update your Personal Information, or if you no longer desire our services, you can contact our privacy manager at the above contact information.
Unsubscribe Requests: If you would like to unsubscribe from our email lists, you can do so by clicking the link to “unsubscribe” at the bottom of any email from us or by emailing: privacy@inkblotholdings.com and providing all of your email addresses that could appear on our email lists, as well as the name of the newsletter from which you would like to unsubscribe.
Updated September 18, 2020