North America: 888.800.2313
International: +44 (0) 845.371.1040
SAT M E T R I X
[ PR I VA CY POL I CY ]
PRIV AC Y PO L I CY
This Privacy Statement explains the data practices of Satmetrix Systems, Inc. (”Satmetrix” or “Us”).
This privacy statement covers the sites www.satmetrix.com and www.ccsurvey.com. Par t I
describes our data practices with respect to Personal Data (as defined below) that Satmetrix
processes on behalf of its clients; and Part II describes our data practices with respect to information we collect about our business contacts and other visitors to the Satmetrix website. The general provisions in Part III apply to our data practices in both Part I and Part II.
Satmetrix has been awarded TRUSTe’s Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe’s program requirements including
transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program does not cover information that may be collected through downloadable software and only covers the web sites www.satmetrix.com and www.ccsurvey.com. TRUSTe’s
mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions.
Satmetrix complies with the U.S.-E.U. Safe Harbor framework and the U.S.-Swiss Safe Harbor
framework as set forth by the U.S. Department of Commerce regarding the collection, use, and
retention of pers onal data from European Union member countries and Switzerland. To learn more
about the Safe Harbor program, and to view Satmetrix’s certification, please visit http://www.export.gov/safeharbor/. If you have any complaints regarding our compliance with the Safe Harbor
you should first contact us. If contacting us does not resolve your complaint, you may raise your
complaint with TRUSTe by Internet at: http://www.truste.com/consumers/watchdog_complaint.php, fax at 415-618-3421, or mail at Watchdog Complaints, TRUSTe click here for mailing
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bor/. If you have any complaints regarding our compliance with the Safe Harbor you should first
cont act us. If contacting us does not resolve your complaint, you may raise your complaint with
TRUSTe by Internet at: http://www.truste.com/consumers/watchdog_complaint.php, fax at
415-618-3421, or mail at Watchdog Complaints, TRUSTe click here for mailing address. If you are
faxing or mailing TRUSTe to lodge a complaint, you must include the following information: our
name, the alleged privacy violation, your contact information, and whether you would like the
particulars of your complaint to be shared with us. For information about TRUSTe or the operation
of TRUSTe’s dispute resolution process, see http://www.truste.com/consumers/watchdog_complaint.php or request this information from TRUSTe at any of the addresses listed above. The
TRUSTe dispute resolution process shall be conducted in English.
PART I: PERSONAL DATA PROCESSED ON BEHALF OF SATMETRIX CLIENTS
As a general description of our data processing services, Satmetrix collects (and analyzes) survey
resp onses from our clients’ customers who consent to be contacted or who have pre-ex isting
relationships with the Satmetrix client for which Satmetrix is conducting a survey. As described in
this Part I, Satmetrix does not own the Personal Data that we process.
1. SATMETRIX IS A DATA PROCESSOR
Satmetrix processes, on behalf of its clients (Satmetrix’s “Clients”), Personal Data that has been
collected by or on behalf of those Clients. “Personal Data” means information relating to an identified or identifiable person. Under the United States/European Union Data Protection Safe Harbor
Arrangement (th e “Safe Harbor”), Satmetrix acts as a Data Processor and each Satmetrix Client
acts as a Data Controller. For the purposes of the Safe Harbor and this Privacy Statement: a “Data
Processor” is an entity that processes Personal Data on behalf of a Data Controller; a “Data Controller” is an entity that determines the purposes for which Personal Data are processed. To “process” Personal Data means to carry out an operation or set of operations on such Personal Data,
such as collecting, recording, storing, disclosing, or organizing it. The “Data Subject” means the
person to whom a certain set of Personal Data relate; for example, the person who resp onds to a
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survey.
Arrangement (the “Safe Harbor”), Satmetrix acts as a Data Processor and each Satmetrix Client
acts as a Data Controller. For the purposes of the Safe Harbor and this Privacy Statement: a “Data
Processor” is an entity that processes Personal Data on behalf of a Data Controller; a “Data Controller” is an entity that determines the purposes for which Personal Data are processed. To “process” Personal Data means to carry out an operation or set of operations on such Personal Data,
such as collecting, recording, storing, disclosing, or organizing it. The “Data Subject” means the
person to whom a certain set of Personal Data relate; for example, the person who responds to a
survey.
2. CLIENT INSTRUCTIONS
As a Data Processor, Satmetrix will only process Personal Data pursuant to the instructions of the
applicable Client. Satmetrix may use the services of third party Data Processors to process Personal Data in accordance with purposes identified for such Personal Data by the applicable Client.
Subject to the fo regoing sentence and Section 1 of Part III (”Security Measures”) below, Satmetrix
will not transfer Personal Data to a Third Party (which, for purposes of this Privacy Statement,
means an entity other than Satmetrix an d its applicable Client) without instructions from the applicable Client. Satmetrix will not be responsible for determining the authenticity of any purported
Data Subject’s request to access his or her Personal Data. In the absence of express instructions
to do so from the applicable Client, Satmetrix will not provide a purported Data Subject with
access to his or her Personal Data unless it is demonstrated to Satmetrix’s satisfaction that the
applicable Data Controller has refused such access.
Satmetrix does not review, comment upon, or monitor its Clients’ compliance with their respective
privacy policies, nor does Satmetrix review Client instructions to determine whether they are in
compliance or conflict with the terms of a Client’s published privacy policy.
3. PERSONAL DATA COLLECTION
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Customer satisfaction surveys are initiated to improve the processes and relationships between
our Clients and their customers. Typically a Client’s customers provide the Client with certain
information including their names, companies, job titles, phone numbers, and email addresses and
the Client provides such information to Satmetrix to enable us to process and analyze surveys on
behalf of the Client. In addition, commercial list services may provide Satmetrix with contact information for people who have opted to receive email (”opt-in lists”) on specific topics of interest.
We invite Client customers — via email, telephone, web page banners, web pop-ups, and other
media — to fill out surveys hosted on Satmetrix’s site (i.e., satmetrix.com, ccsurvey.com, or any
successor web site). Participation in these surveys is voluntary. When a survey respondent uses
the Satmetrix site to fill out a survey, our servers (which are hosted by a third party serv ice provider) may collect information indirectly and automatically (through, for example, the use of “cookies”
or your “IP address”) about your activities on the site while responding to the survey. We use this
browsing information, in non-personally identifiable form, for internal purposes such as to help
understand how the site is being used and to improve it, and for systems administration purposes.
We do not link the information we store in cookies to any personally identifiable information you
submit while on our site.
Cookies are small pieces of information stored on respondent’s hard drive, not on our site. Cookies
allow us to better understand how respondents use the site, which in turn helps us focus our
resources on improvements to the site. We use session cookies, which expire when the browser
window is closed, and persistent cookies to keep track of which survey(s) a particular respondent
has answered. A respondent is always free to decline our cookies if her browser permits , but in
that case, the survey site may not operate properly or a respondent may be prompted to fill out the
same survey mul tiple times at a client’s site. An IP address is a number that is automatically
assigned to a co mputer when it is used on a network like the Internet. In some cases the computer’s IP address stays the same from browser session to browser session; but, for computers connecting to the Internet via consumer Internet access providers, the IP address generally varies
from session to session.
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In some cases, we use unique identifiers in email messages, which enable us to determine which
emails have generated responses. This allows us to gauge the effectiveness of certain communications and to exclude those persons who have already responded to a certain message from duplicate messages.
Survey respondents may be required to submit information such as a mailing address in order
receive a gift or other offering (if applicable).
In the email survey invitations we send, we provide an opportunity for recipients to ‘opt-out’ of
receiving future email survey invitations on behalf of the applicable Client.
4. USE OF NORMATIVE DATA
Satmetrix provides research services to its Clients in which Satmetrix analyzes a Client’s customer
performance data in comparison with that of other companies in the same industry as the Client
(”Normative Research”). However, Satmetrix does not process any Personal Data in performing
Normative Research: (a) Satmetrix uses only non-Personal Data (i.e., data that includes no personally identifiable information or unique identifiers that could later be used to refer to the personally
identifiable information to which the data was once associated) in performing this Normative
Research, and (b) Satmetrix discloses only non-Personal Data in aggregate form (”Normative
Data”) to its Clients who have requested Normative Research.
PART II: BUSINESS CONTACT INFORMATION
In addition to the data we process on behalf of our Clients, Satmetrix also processes (on its own
behalf) information about our Clients and the individuals who represent our Clients, as described in
this Part II.
1. COLLECTION AND USE OF BUSINESS CONTACT DATA
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The individuals who represent Satmetrix’s Clients or potential Clients (”Business Contacts”) may
voluntarily provide their contact information and related data (collectively “Business Contact
Data”) to Satmetrix by various means, including telephone, email, postal mail, the “contact us” or
“download” page on the Satmetrix site, or other means. The Business Contact Data submitted to
Satmetrix is used to communicate with and provide services for Clients and potential Clients.
Satmetrix will change, update or delete Business Contact Data when a request by the applicable
Business Contact is requested. To send a request please fill out the contact request form or send
mail to Satmetrix Systems, Inc.; 3 Twin Dolphin Drive, Suite 225, Redwood City, CA 94065 USA. We
will respond to your request for access within 30 days.
When a Business Contact accesses rep orts through Satmetrix’s servers, or otherwise uses the
Satmetrix site, our servers may place persistent cookies on the Business Contact’s computer in
order to keep track of the Business Contact’s personalized settings.
In some cases, we use unique identifiers in email messages sent to Business Contacts, which
enable us to determine which emails have generated responses. This allows us to gauge the effectiveness of certain communications and to exclude those Business Contacts who have already
responded to a certain message from duplicate messages.
Periodically, we may have special offers that collect personal information. That information would
be used for the stated purpose and as consistent with this privacy statement. These special offers
include but are not limited to promotional giveaways, newsletters and fact kits. Out of respect for
our users’ privacy we provide a way to opt-out of our newsletter and other promotional communications. Users may opt-out by clicking on the unsubscribe link that’s included in these communications.
In addition to Business Contact Data, Satmetrix may collect non-personally identifiable information indirectly and automatically about visitors’ use of the site, including the web pages viewed on
the site, the web page from which the visitor linked to the site, the web page to which the visitor
linked from the site, and information ab out the browser the visitor is using (through, for example,
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the use of “cookies” or the visitor’s “IP address” (see explanations in Part I.3 above)) ab out the
visit or’s activities on the site. We use this browsing information for internal purposes such as to
help understand how the site is being used and to improve it, and for systems administration purposes.
2. DISCLOSURE OF BUSINESS CONTACT DATA
Generally, Satmetrix does not provide Business Contact Data or other data to third parties. Satmetrix may provide Business Contact Data or other data to third parties to the extent such third
part ies provide operational assistance (i.e., outsourced or third party services) to Satmetrix and
then only for that purpose. Satmetrix may share Business Contact Data or other data with its
corporate family, including its parent company, subsidiaries, or other companies under common
control with Satmetrix for the same operational assistance.
PAR T III: GENERAL
1. SECURITY MEASURES
Satmetrix uses i ndustry-standard secur ity measures to protect the integrity and confidentiality of
Business Contact Data as well as Personal Data it processes on behalf of Clients, including, in
appropriate circumstances, the use of firewalls, restricted access, and encrypted transmissions.
Satmetrix limits access to Business Contact Data or Personal Data to those persons in Satmetrix’s
organization who have a business need to process such Business Contact Data or Personal Data.
However, no company, including Satmetrix, can fully eliminate the security risks associated with
such Business Contact Data or Persona l Data.
Due to factors beyond Satmetrix’s control, Satmetrix cannot ensure that Business Contact Data or
Personal Data will not be disclosed to third parties. For example, Satmetrix may become legally
obligated to disclose such data, or, despite precautions, third parties may circumvent security
measures to intercept or access such data.
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2. CORPORATE FAMILY AND SUCCESSORS
If another company acquires Satmetrix or substantially all of its assets, that company will (a)
succeed to ownership of the Business Contact Data held by Satmetrix and will possess the Personal Data held by Satmetrix, and (b) assume the rights and obligations regarding such Business
Cont act Data and Personal Data described in this Privacy Statement.
3. QUESTIONS
Questions, comments, or complaints about this Privacy Statement or Satmetrix’s data practices
please fill out the contact request form or mailed to Satmetrix Systems, Inc.; 3 Twin Dolphin Drive,
Suite 225, Redwood City, CA 94065 USA. We will respond to your request for access within 30 days.
Any questions, comments, or complaints about the data practices (including without limitation
compliance with the data privacy principles of notice, choice, onward transfer, access, security,
data integrity, or enforcement) of a Satmetrix Client for whom Satmetrix processes data, should be
directed to that Client.
4. Notification of Changes
If we decide to change our privacy policy, we will post those changes to this privacy statement, the
homepage, and other places we deem appropriate so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We will use
information in accordance with the privacy policy under which the information was collected. If,
however, we are going to use users’ personally identifiable information in a manner different from
that stated at the time of collection we will notify users by posting a prominent notice on our Web
site. Before we make material changes to this policy, we will notify you here, by email, or by means
of a notice on our homepage.
5. Choice / Opt-out
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We provide you the opportunity to ‘opt-out’ of having your personally identifiable information used
for certain purposes, when we ask for th is information. For example, if you request information but
do not wish to receive any additional marketing material from us, you can indicate your preference
on our contact form. If you no longer wish to receive our newsletter, surveys or promotional communications, you may opt-out of receiving them by following the instructions included in each
correspondence or by emailing us at privacy@satmetrix.com. In addition you may contact us at
877-229-9674 or by mail at Satmetrix Systems, Inc.; 3 Twin Dolphin Drive, Suite 225, Redwood City,
CA 94065 USA. You will be notified when your personal information is collected by any third party
that is not our agent/service provider, so you can make an informed choice as to whether or not to
share your information with that party.
6. Legal Disclaimer
We reserve the right to disclose your personally identifiable information as required by law and
when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial
proceeding, court order, or legal process served on our Web site.
7. Data Retention
We will retain your information for as long as your account is active or as needed to provide you
services. If you wish to request that we no longer use your information to provide you se rvices
contact us at privacy@satmetrix.com. We will retain and use your information as necessary to
comply with our legal obligations, resolve disputes, and enforce our agreements.