OUR COMMITMENT TO PRIVACY

Illuminas Global (“Illuminas”) is a professional marketing intelligence agency that uses scientific methods to gain insight to specific issues relevant to our clients. As of 24 Aug 2023, Rockbridge has joined Illuminas.

Any information that you supply to Illuminas is used solely for legitimate research or statistical purposes and will never result in an attempt to sell you anything based on your responses. We strictly adhere to practices and guidelines that respect the individual’s right to privacy and extend the following assurances to all research projects:

Notification:

• In obtaining your cooperation, we will not mislead you about the nature of the research or the use that will be made of the findings.

• We will not send you unsolicited email or pass on your email address(es) to others for this purpose. If we want to send you future email or contact you using other methods, we will ask your explicit permission for this.

• On rare occasions, we may use cookies (A cookie is a piece of information that webservers send to your browser file when you access a website. Then when you come back to a website again, that website will detect whether you have cookies on your browser file.) and other similar devices sparingly for quality control, validation, or to prevent bothersome repeat surveying. You can configure your browser to notify you when cookies are being placed on your computer or to reject cookies altogether.

• Illuminas utilizes a network of third-party vendors for data processing and analysis, which are contractually obligated to solely use your information for research and statistical purposes.

Choice:

• Should you wish to opt out from future surveys, please notify us via email at [email protected] or by writing the address noted below. It is our goal torespond to each email within one working day, but please allow 1-2 weeks for complete removal of your data.

• All information you provide is confidential and reported anonymously. In rare occurrences, we may ask for permission to use certain responses in a form that would allow you to be personally identified. In such cases, this information will only be passed on with your expressed consent and only for the purposes stated.

• Your cooperation is always voluntary. You are entitled at any stage of the interview or survey, or subsequently, to ask that part or all your information be destroyed or deleted. Wherever reasonable and practical, we will carry out such a request.

• We will always give you an opportunity to choose opt-out before your Personal Information is (1) disclosed to a third party (other than an agent doing work at our direction), or (2) to be used for a purpose that is materially different than that for which it was originally collected or subsequently authorized by you. The only exception to this choice for both sensitive and non-sensitive Personal Information would be where we are required to disclose your Personal Information pursuant to governmental or judicial order, law or regulation to meet national security or law enforcement requirements.

• We will not knowingly interview those under the age of 15 without first getting permission from their parent or guardian.

Onward Transfer:

• All Third parties are contractually obligated to keep your information secure and intact.
• Third parties are solely contracted to use the information provided for research or statistical purposes. No other use of your information is authorized.

• Illuminas may be required to disclose personal information in response to lawful requests from public authorities including to meet national security or law enforcement requirements.

• In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-U.S. Data Privacy Framework or Swiss-U.S. Data Privacy Framework, Illuminas may remain liable.

Access:

• Information collected by Illuminas is processed solely for research or statistical purposes.

• If you wish to access, amend, or confirm that Illuminas has personal data relating to you, or if you wish to correct or delete your Personal Information if it is inaccurate, please notify us at [email protected]. We will respond to your request within a reasonable time.

• We encourage you to email [email protected] to address any concerns or questions you may have.

Security:

• Our web site and internal network has security measures in place to protect the loss, misuse, and alteration of the information under our control.

• Only authorized employees and contractually bound partners have access to the information you provide to us. They have access solely for research, statistical analysis, and quality control purposes.

• Personal data is stored for twelve (12) months after the research project is complete, or for as long as is necessitated by the purposes for which it was originally collected.

• Illuminas does not sell or rent any personally identifiable information to third parties.
• In the event of reorganization, merger, or sale, we may transfer any and all personal information to the relevant third party.

• Illuminas does not collect or have access to any personal financial information (e.g., social security, credit card, bank account).

Data Integrity:

• Illuminas shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual.

• Illuminas shall only collect non-sensitive information in the form of contact information (e.g., name, email address) for the purposes of our research.

• Illuminas shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

Enforcement:

• Illuminas utilizes a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information in accordance with the principles.

Personal Data Collection:

• The Personal Data that is processed may include your name, address, telephone number, e-mail address, date of birth, and other similar information. Illuminas may collect Personal Data directly from you when you voluntarily provide it to Illuminas or Illuminas may obtain Personal Data from our Panel Owners, Clients or market research firms who have obtained a Participant’s consent. For Panel Members of a panel of one our Panel Owners, Illuminas will collect data in accordance with their instructions.

• Illuminas may also obtain Personal Data from database owners who have assured us that their databases comprise only individuals who have consented to be included and have their Personal Data shared. Finally, Illuminas may collect and use Personal Data obtained from publicly available sources, such as telephone directories.

Automated Data Collection:

• Illuminas may collect certain information automatically. Depending on the country in which you live, such information may be considered Personal Data. Such information includes, but is not limited to, information about your device and device capabilities including, but without limitation, the device operating system, cookie information, IP address, device type, browser type, and other information that alone or in combination may be used to uniquely identify your device.

CCPA Privacy 

Your Rights under the CCPA

Under this Privacy Policy, and by law if You are a resident of California, You have the following rights:

• The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
• The right to access / the right to request. The CCPA permits You to request and obtain from the Company information regarding the disclosure of Your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party’s direct marketing purposes.
• The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell Your Personal Data to third parties. You can submit such a request by visiting our “Do Not Sell My Personal Information” section or Web page.

• The right to know about Your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:
  • The categories of Personal Data collected
  • The sources from which the Personal Data was collected
  • The business or commercial purpose for collecting or selling the Personal Data
  • Categories of third parties with whom We share Personal Data
  • The specific pieces of Personal Data We collected about You
• The right to delete Personal Data. You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months.

• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your Consumer’s rights, including by:
  • Denying goods or services to You
  • Charging different prices or rates for goods or services, including the use of. discounts or other benefits or imposing penalties
  • Providing a different level or quality of goods or services to You
  • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

 
Exercising Your CCPA Data Protection Rights

• In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can email or call Us as detailed below or visit our “Do Not Sell My Personal Information” section or Web page.

The Company will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Do Not Sell My Personal Information

• We do not sell any personal information.
• Please note that with regard to Usage Data, any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

• The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If You change browsers or delete the cookies saved by Your browser, You will need to opt out again.

Mobile Devices

• Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

• “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices

 “Limit Ad Tracking” on iOS devices

• You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA

Please note We do not respond to “do not track” (DNT) signals in browsers because no DNT standard has been adopted. If a DNT browser mechanism is in place, We will still track, plant cookies, or use advertising as described in this Privacy Policy.

Note that some third-party Websites do keep track of Your browsing activities. If You are visiting such Websites, You can set Your preferences in Your Web browser to inform Websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your Web browser.

Your California Privacy Rights (California’s Shine the Light law)

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.

If You’d like to request more information under the California Shine the Light law, You can contact us using the contact information provided at the bottom of this privacy policy.

Amendments:

This privacy policy may be amended from time to time consistent with the requirements of the EU-U.S. Data Privacy Framework, CCPA, and other applicable laws or regulations. We will post any revised policy on this website. This version of Illuminas’ privacy policy was last modified on 28 July 2023.

Commitment to Protect

Illuminas complies with the EU-U.S. Data Privacy Framework and the Swiss-U.S. Data Privacy Framework(s) 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. Illuminas has certified to the Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles with respect to such information. If there is any conflict between the terms in this privacy policy and the EU-U.S. Data Privacy Framework Principles, the EU-U.S. Data Privacy Framework Principles shall govern. To learn more about the EU-U.S. Data Privacy Framework program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. and Swiss-U.S. Data Privacy Framework Principles, Illuminas commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Illuminas at: 

RE: EU-U.S. Data Privacy Framework
Jacob Manhart
PO Box 152049, Austin TX, 78715
United States of America

Illuminas has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Data Privacy Framework Principles to the Insights Association Data Privacy Framework Services Program, a non-profit alternative dispute resolution provider located in the United States and operated by the Insights Association. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.insightsassociation.org/Resources/Data-Privacy-Framework/Information-for-

EU-Swiss-Citizens-to-file-a-complaint for more information and to file a complaint. These dispute resolution services are provided at no cost to you. 

Illuminas is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”).

Under certain limited conditions, individuals may invoke binding arbitration before the Data Privacy Framework Panel created by the U.S. Department of Commerce and the European Commission.

Contact Information

You may contact us at [email protected] or via mail at Attn: Privacy Policy, 3801 South Capital of Texas Hwy, Ste 200, Austin, TX 78704 to express or discuss any concerns with an individual survey or questions regarding our general research practices. We are members of the Insights Association and follow their codes of conduct for market research. All research projects are also conducted in accordance with the provisions of the ICC/ESOMAR International Code of Marketing and Social Research Practice.