Market Force Information LLC, and its wholly owned subsidiaries (“Market Force Information”, “we”, “us” or “our”), is committed to protecting and respecting your privacy.
Effective Date 18th September 2020 Version 5.0
SCOPE OF POLICY
If you are a prospective or current client, visitor to our website, or an independent contractor, this policy applies to you fully.
You should read this policy carefully to understand our practices regarding your personal data and how we will treat it and protect it.
HOW AND WHY WE PROCESS YOUR DATA
If you are a prospective or current client, visitor to our website, or independent contractor, then we determine how and why we process your data. From the moment you visit our website, we are collecting personal data. Sometimes you will provide us with personal data and other times, personal data will be collected automatically or generated manually.
We do not request or require you to provide any special categories of personal data including for example genetic data, biometric data for the purpose of uniquely identifying a natural personal, or information relating to your racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, or sexual orientation. If we become aware of any such data having been submitted to us, we will, where reasonably practicable, endeavor to delete it.
What do we collect?
The personal information you give us during your registration (either via the micro-sites or via download of the Eyes:On™ mobile application) may include your first and last name, address, e-mail address and phone number, bank account information, date of birth, age, nationality.
During registration, we will capture IP address.
Following registration, you will be issued with a username (or ‘Shopper ID’) and password and will have opportunity to provide us with additional information on your life style habits and financial information, which will help us show you the most suitable assignments. We will also keep a record of the assignments you complete for us.
If you contact us by mail, email, web or phone, we may keep a record of that correspondence.
If you use the Eyes:On™ mobile application, we may also use GPS and geolocation technology to determine your location and provide locationbased services. These services require your Personal Data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can deactivate this feature at any time by turning off access via your device settings.
How is it used?
When you apply to register with us as a mystery shopper or auditor, we may use information we collect from you to:
- consider your suitability to perform those services;
- include you on our list of mystery shoppers;
- manage your account;
- collect and maintain historical information about your mystery shopping assignments and payments and administer payments;
- carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
- provide you with information about shopping opportunities and other services we offer that are similar to those that you have already enquired about;
- notify you about changes to our service; or
- ensure that content from our Site is presented in the most effective manner for you and for your computer, or;
- ask for your participation in optional surveys to provide information regarding your buying habits, shopping preferences and related information
Why do we use it?
We primarily process your personal data because it is necessary for a contract you have with us, or because we have asked you to take specific steps before entering into that contract.
We also process some personal data for our own legitimate interest, provided those interests don’t affect your rights and interests. These legitimate interests are maintaining the integrity of our independent contractor database, improving our services, and enabling us to enhance, customise or modify our services and communications.
Prospects and Commercial Requests
What do we collect?
When you download marketing collateral or contact us to schedule a briefing, we collect and maintain Personal Data so we can include you in our marketing database, comply with your request, and send you information on our products and services. Personal data we collect for these purposes usually include your name and contact information. Where you contact us by phone, we may also keep a copy of that correspondence.
You may unsubscribe from our emails at any time by clicking on the “unsubscribe” link in the emails you receive from us.
How is it used?
We may use information we collect from you to:
- provide you with the information requested;
- provide you with information that are similar to those that you have already enquired about;
- notify you about changes to our service
Why do we use it?
We primarily process your personal data to support your request, or because you have asked indicated that you are considering entering into a contract.
Further direct marketing is necessary for the purposes of legitimate business interests pursued by us. These legitimate interests include: gaining insights from your behaviour on our website to enhance our website, determining whether marketing campaigns are effective and enhancing and customising our services.
What do we collect?
We use personal details such as your name, telephone number and email address, as well as job title or position in order to manage contracts and agreements that exist between us, as well as provide you with the services contracted with use.
How is it used?
We use the information provided to us to:
- manage your account;
- carry out our obligations arising from any contracts entered into between you, your employer, and us and to provide you with the information and services that you or your employer request from us;
- notify you about changes to our service
- We also use the information ask for your feedback on our products and services
Why do we use it?
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
When we ask for feedback, this is necessary for the purposes of the legitimate business interests pursued by us.
Market Force as a Processor or Service Provider
When you visit our website or access our services, we will automatically collect certain information such as the IP address or domain name of the device used and the URI address. We also use the following types of cookies:
- Session cookies - these are cookies that your computer stores only for that browser session. Once you close your browser, the cookie is deleted. These cookies allow you to navigate around the site using your logon details without having to login again on every page.
- Google Analytics tracking cookies - this cookie allows us to understand more about the websites visitors, such as the number of visitors, details of the devices used to access the site or our services, which pages are accessed and the various time details per visit.
MARKET FORCE AS A PROCESSOR OR SERVICE PROVIDER
ADDITIONAL USES OF PERSONAL DATA
In addition to the above, sometimes we may need to process, share or disclose your personal data for other, non-routine or unexpected reasons. We will only ever do this in exceptional circumstances and always in accordance with data protection laws. Apart from the uses described in the section above, we may process and disclose your personal data for any of the following reasons:
- if a third party acquires any Market Force Information company, or substantially all of its assets, in which case Personal Data held by it about its customers will be one of the transferred assets and the buyer is likely to seek information about its independent contractors. In such cases we may disclose your Personal Data to the prospective or ultimate purchaser and/or their legal and other professional advisers, irrespective of where in the world any of them are located. Where reasonably practicable, we will endeavour to anonymise the data until contracts have been signed and/or request the recipient to contract to keep the data secure and confidential and, if the transaction does not proceed, either to return the data to us, or to destroy it. (Once contracts are signed, the buyer is committed and it will usually be necessary to remove the anonymization so that the buyer can make more concrete plans for dealing with customers and independent contractors).
- if we are under a duty to disclose or share your Personal Data in order to comply with any legal or regulatory obligation or request, including lawful requests by public authorities to meet national security or law enforcement requirements; or
- to protect the rights, property or safety of Market Force Information, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; or
- when compiling aggregated or anonymous information for third parties for the purpose of identifying buying habits, shopping preferences and other related information.
We do not sell personal data to third parties for commercial purposes and we only share or disclose your data as authorised in this Policy.
In the case of individuals located in countries where the GDPR applies, we will process any request for disclosure in accordance with the GDPR, and you may be notified and informed of your choices relating to the disclosure in accordance with the law that applies to you.
HOW WE KEEP YOUR DATA SECURE
As a technology-based company, we recognise how important appropriate information security is to protect all types of data and information, including above all personal data.
In order to provide a level of continuous operation and security, we have implemented a comprehensive information security programme in line with international standards and best practices. The programme includes a series of technical and organizational measures designed to protect personal data from loss, misuse, unlawful processing, unauthorized access, disclosure, copying, alteration and destruction. These include implementing access controls, maintaining audit logs, intrusion detection software, anti-virus or malware protection and system integrity tools to further protect data stored on these databases.
We also undertake annual training on data protection and information security to make sure everyone at Market Force understands their roles and responsibilities.
Social Media Features
Some of our sites includes features from social media websites, such as the Facebook Like button. 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 are either hosted by a third party or hosted directly by us.
Where we Process Your Data
We process personal data at our offices in the United Kingdom, United States and Canada, as well as in any third party data processing facility operated by a third party. This means that your personal data might be accessed by employees in other offices, but always in accordance with our information security policies and procedures.
As a global company, it may be necessary at times to transfer the Personal Data we collect from you and about out to destinations outside of the European Economic area (“EEA”), within the Market Force Information group of companies, with our third-party processors, or with our partners. We only transfer Personal Data if it is necessary of a particular purpose, or we have a legitimate business interest in doing so.
For transfers of Personal Data outside of the EEA, we only rely on approved and defined legal mechanisms to ensure that we protect data at all times. We assess all transfers and use Standard Contractual Clauses or other ‘adequacy’ protections, such as Adequacy Decisions. For transfers between Market Force Information group companies, we have in place an intra group transfer agreement, incorporating Standard Contractual Clauses.
Third Party Data Processing
Like many other companies, we use third parties to help host our applications, send emails, etc. When we work with third parties, we make sure that we have assessed their capacities and are confident they can protect your data in the same way we do, and to the same high standards.
Here are the details of our main third-party service providers, and what data they collect or we share with them, where they store the data and why they need it: Link to Subprocessors
The amount of time we hold your personal data will vary but shall be kept for no longer than is necessary for the purposes for which it is being processed.
Remember that if you work for any of our clients or provide personal data to a Market Force client through any of our services, we only process your data in order to provide our services to our clients or upon their written instruction. This includes how long we will retain your personal data for.
When deciding on the retention period, we take into consideration the following:
|Data Subject||Criteria for Retention of Personal Data|
We will retain your personal data indefinitely whilst you are an active client. When you stop accessing services, we will retain some restricted personal data for a period of time to allow you to download any client data, usually 30 days unless we agree a different period.
|Independent Contractors||We will retain your personal data indefinitely whilst you are actively completing mystery shopping assignments for us.
When you stop completing mystery shopping assignments, we will retain some restricted personal data for upto 6 years in order to respond to any requests, support or defend any claims, and provide evidence of financial transactions in accordance with statutory retention periods. We will delete all other personal data.
|Prospects and Commercial Requests||We will retain your personal data for as long as necessary to provide you with the information requested or with information similar to those that you have already enquired about, or until you opt out of receiving marketing communications.|
Typically, you have the following rights:
- The right to access your personal data unless access is subject to a legal exception. Exceptions may apply for example where the data is the subject of confidential legal advice and is covered by legal professional privilege. In some countries, an application for access may be refused where it involves disproportionate effort, or inevitably requires the disclosure of the Personal Data of other individuals who have not provided their consent to the disclosure or to have your Personal Data;
- The right to restrict processing and have your Personal Data corrected if it is inaccurate or incomplete;
- The right to have your Personal Data erased if they are no longer necessary or required in relation to the purposes and no there are no other overriding legitimate grounds for us to continue processing it;
- The right to opt out if your Personal Data is to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorised by you, and
- The right to complain to a supervisory authority if you think your rights have been infringed.
You can make a request to exercise your rights by clicking the following button:
We will respond to these requests in accordance with the laws that apply to you. When you make your request, the personal data you provide to us will be held on our secure, privacy management platform.
Access requests are free however we reserve the right to charge a reasonable fee to comply with requests when such request is manifestly unfounded or excessive.
Attention: Data Protection Officer
Tel: +44(0)1908 328 000
In the event an EU user is still concerned that Market Force Information is not complying with their obligations under the GDPR and is not handling their data responsibly and in line with good practice, then they may raise a concern with the UK Information Commissioner’s Office. The ICO can report a concern online here, https://ico.org.uk/concerns/handling/ or by phone on 0303 123 1113.
When you contact us, please make sure that you provide as much information as possible, so we can quickly identify your records and get back to you.
If you live in Canada, questions, comments and requests can also be addressed to Market Force Information Canada, Inc. 610-201 Portage Avenue, Winnipeg, Manitoba, Canada R3B 3K6. For Canadian users, any complaint will be responded to within thirty (30) days.
If you live outside North America, questions, comments and requests can also be addressed to Data Protection, Market Force Information (Europe) Ltd, Scorpio House, Linford Wood Business Park, Rockingham Drive, Milton Keynes, MK14 6LY
Our legal status under UK data protection law is that of a data controller, and we have notified the Information Commissioner’s Office in accordance with the GDPR with registration number Z9429070.