Privacy Policy
Introduction. This Information Usage, Privacy & Security Policy ("Policy") covers personally identifying information ("PII" or "information") collected through paidsurveytopia.com ("Site") or any site powered by Thinkaction.com. "You" means a user of this Site.
Description of Our Business. Our business is based on the collection of information, directly or indirectly, from you. We, or others to whom we transfer it, share it in the United States and all over the world with third parties who want to know what you think, want to interest you in something such as a product or service, or who simply get some kind of credit for contacting you or having you contact them (collectively, "Third Party Marketers" or "TPMs"). TPMs include but are not limited to our affiliate Greenfield Online ("GO"), an Internet survey provider. Sometimes we try to match you to a TPM who is looking for someone like you.
We let you consider opportunities from TPMs in two basic ways:
1.First, we take registration information from you and then see if you might match or be interested in opportunities with GO or from a small number of TPMs; and
2.Second, if you aren't interested in anything we showed you, we transfer you to the website of a type of TPM that we call a third party "gatekeeper" ("TPG"), i.e., a company whose business is to find a larger world of TPMs in which you might be interested; we also transfer some of your profile information with the TPGs so that they can try to figure out what TPM opportunities you might want to find out about.
In either case, if you click on a TPM opportunity we will count that as your instruction for us to forward on your behalf, some of your profile information to those TPMs as well as any additional information that you enter in connection with a particular opportunity.
When you are on a TPG's site, or if you decide to deal with a TPM who contacts you, read their respective privacy policies to learn what information they collect and what may happen to it and the other PII that we transferred to either of them. This is important because once we implement your instruction to transfer your PII to the TPM, it is, effectively, out of our control even if there are restrictions between us and any TPM. Any such restrictions do not prohibit the above or the other business practices described in this Policy, and in any event, we cannot make TPMs (including TPGs) comply with their contracts and we do not take any responsibility for any noncompliance by them.
You might be a marketer's dream, but if you do not want to receive on a regular basis ads or opportunities (such as to take surveys), or if you are not comfortable with having us transfer your PII to TPGs and numerous TPMs, or with having them possibly transfer it to still more people, then this Site is not for you and you should exit now. When you use our Site (or a TPG or TPM site, or otherwise deal with any of us) and are affirmatively asked for PII, do not provide any PII that you do not want provided to TPGs, TPMs and their transferees.
How does this Policy relate to my use of the Site? This Policy is part of and incorporated into our Terms of Use, the contract between you and us that governs this Site. That means provisions of those terms impact this Policy, so if you have not read the Terms of Use, read them now by clicking on the link.
Who We Are; Contacting Us & Our Address for Legal Notices; Notices to You. We are ThinkAction ("ThinkAction", "Site", "we", "us" or "our") a division of Greenfield Online, Inc. ("GO") (although we may be changing our organization form to become a subsidiary or other affiliate). Our telephone number is 203-834- 8585 and for customer service matters you may email us at security@thinkaction.com To send us a legal notice, mail it by certified mail (return receipt requested) at: ThinkAction.com, 21 River Road, Wilton, CT 06897, U.S.A., Attn. Legal Department and General Counsel ("Our Address for Legal Notices"). When we need to contact you, including when we give a legal notice, you agree that we may give it to a postal or email address that we have for you and/or may post notice on the Site. It is important for you to update your address information periodically.
Your Agreement with Us. By providing PII or other information to us or by using our site, you: (i) agree to this policy, including (without limitation) all of the above and below, (ii) agree that we may rely without liability on your instructions (such as by clicking on TPM opportunities) to Disclose (as defined below) your PII, including but not limited to transfers of it in and out of the U.S. and other countries by us, our affiliates, TPGs, TPMs, advertisers and transferees of any of the foregoing; and (iii) acknowledge that if privacy is of concern to you, you will investigate the privacy policies of TPGs and other TPMs and of providers of advertisements on our Site.
Information We Collect That You Do Not Affirmatively Provide. Our Site contains cookies or other tracking mechanisms placed there by us or TPMs (cookies are a small file our Site transfers to your computer's hard disk to allow our server to "remember" specific information, e.g., to insert your PII so you can avoid retyping). We use persistent, identifying cookies to remember your information and to link your activities to you. Our cookies collect at least the following:
1.the domain name and host from which you access the Internet and the Internet address of the site from which you direct-linked to ours;
2.the date and time you access the Site and pages you visit;
3.your computer's IP address and information about its operating system, and the Web browser you use; and
4.information to combat fraud or misuse.
While you can take steps to disable cookies, if you do, the Site won't function as we have designed it. In our e-mails to you, we use "pixel tags" to determine if your email software or service can display html-formatted e-mail (this helps us optimize the size of our e-mail messages and conserve bandwidth). TPM pixel tags might also be present on our Site or in their email messages. We may also collect public and non-public information from you or third parties, and combine it with PII collected through the Site.
Some TPMs might use their cookies on our Site or in their messages to you. If you click on an advertisement, for example, a cookie might be placed on your computer. The same thing can happen if you click on an opportunity from a TPG or TPM, so you should read their privacy policies.
Information Collected Via Advertisements. We work with third parties to provide ads and promotions through the Site and to assist us in managing customer information and to communicate with you. These parties include, but are not limited to Avenue A [ www.avenuea-razorfish.com/ ], Advertising.com [www.advertising.com/] and DoubleClick.net [ www.doublecclick.net ] To find out how these kinds of companies tend to collect and use PII, click on the links to their websites and review their privacy policies. We do not control these or other advertising companies or their privacy policies; also, their practices and policies may change from time to time. In short, you may wish to visit their sites periodically to check their policies.
Information We Collect That You Do Affirmatively Provide. During registration or in connection with particular TPM opportunities, we collect basic and some very detailed PII when you are willing to provide it. Don't affirmatively provide any PII that you don't want to be widely shared or that you are not legally authorized to provide. The more information you provide, the better we or a TPG may match you with TPMs (when matching is relevant), but it is your choice whether to provide that PII. If you decide not to provide it to us, we will simply try to match or share the PII that you do give us (although there will be some PII that we require, in which case your choice will be to provide it or not to participate). categories to see the kinds of PII that we tend to ask you to provide; TPGs and other TPMS may ask you to provide different categories of information so you need to read their policies.
Information We Do Not Collect. We don't collect payment information and if anyone tells you that we need it, don't believe them. For example, we do not collect credit or debit card information, any financial account numbers or other account access information, or full Social Security numbers (except in the limited circumstances described in the next paragraph). Please contact security@thinkaction.com immediately should you receive a request for such information from a source that suggests we are involved. If a TPG or TPM asks for this type of information, you will need to decide whether to provide it based on the type of transaction in which you are engaging.
We will collect your social security number if you win a sweepstakes or earn incentives and we are required to include your SSN in reporting the value of rewards you have earned to government or taxing authorities. Then, your receipt of the incentive or reward is conditioned on providing your SSN.
Children. TPMs are very interested in information relating to children and many products and services are offered to families with children. Accordingly, we may ask for information about children but we do not want to collect it from them. Do not provide us any PII unless you are at least 13 years of age. If a child under 13 has provided PII, a parent or guardian may so inform us by writing us at our Address for Legal Notices and we will use commercially reasonable efforts to delete it from our database, subject to applicable law and this Policy. For more information about children's privacy on the internet, you may wish to visit http://www.ftc.gov/bcp/conline/edcams/kidzprivacy/index.html to learn about some commercially available Internet protection measures.
What We Will Not Do with The PII We Collect. This Policy reveals that we make wide use of PII, but here's what we will not do with it (subject to applicable law): we will not simply sell or transfer your PII without regard to this Policy or the business we describe in it. Instead, we will provide PII to TPGs and other TPMs as described in this Policy (as now existing or later amended). What we will or won't do, however, is not the end of the story. At least one TPG for example, reserves the right in its privacy policy to use the PII we disclose to it for any legally permissible purpose in its sole discretion. So as we've said, if you don't want wide use of your PII, do not use this Site or supply the PII to us or a TPG or other TPM.
What We Tend to Do with The PII We Collect. We reserve the right to do the above and the following worldwide with PII we collect (except for what we said above that we will not do): use, access (or bar access to), process, disclose, display, share, transfer, store, sell, lease, retain, commingle, investigate, verify, prove and otherwise deal with PII, voluntarily or as required by and subject to law (collectively "Disclose").
•We automatically (and usually right away) Disclose PII to GO so that it may consider whether to tell you about a survey for one its customers. If it does, GO will contact you. If you decide to participate, all of your subsequent dealings with (and additional information you provide to) GO will be pursuant to the GO terms of use and its privacy policy instead of ours.
•We will show you a list of opportunities from a limited number of TPMs; if you don't deal with GO or don't click on one of those opportunities, then we will transfer you to a TPG site where you can see more TPM opportunities. We will already have given the TPG some of your profile PII so that, for example, it can decide what opportunities to show you. The information that we typically provide to TPGs is shown in red in the Categories list.
•If you click on any TPM opportunity, you may be asked to provide more PII. You will know what that extra PII is because you will need to enter it. If you click on any TPM opportunity, we will count that as your instruction for us to forward on your behalf, some of your profile information to those TPMs as well as (i) any additional PII that you enter in connection with a particular opportunity, and (ii) information that the TPM might subsequently request from us that we have in your registration information. Typically, we will not keep a copy of the extra PII that you provide in response to particular TPM opportunities, although we reserve the right to do so; the TPM to whom PII is sent, however, might keep both the extra information and the registration information that we send.
•You might hear from a TPM by telephone, e-mail, postal mail, or our Site might transfer you to a TPG.
oYou have no obligation to deal with any TPM, including TPGs. You will need to decide whether to deal with the TPM and whether to provide any additional PII in connection with a TPM opportunity. The part of your registration information that is sent to the TPM, and any additional PII that you enter in connection with a TPM opportunity, will be subject to any TPM privacy policy or other agreements or the TPG and/or relating to your dealings with any TPMs. When you are on the TPG's page, there should be a link to the TPG's privacy policy – read it before you click on a TPM opportunity.
oThis Policy only applies to your dealings with us and only to the PII that we keep. Once we Disclose PII to a TPM, we effectively lose control of it even though we will contract with TPGs, for example. However, contracts do not ensure performance, we cannot make TPGs or other TPMs comply with their contracts, and we do not take any responsibility for any noncompliance by them. Accordingly, do not provide any PII on our Site or to a TPG or other TPM that you would not want a TPM to be able to use under a "worst case" policy that a TPM might have.
•We store the information you provide during registration so that we can periodically see if there's a match to TPM opportunities or surveys, or in case a new TPM would like to see your PII. The TPGs may store it for as long as they think they need it for their business.
•We Disclose PII to third party service providers (such as emailers etc.) to enable them to provide services to or for us, and we Disclose PII to enforce, actual or potential transactions, contests, requests, actions, applications, and rights and defenses.
•We use IP addresses collected by cookies to analyze trends, administer the Site, track visitor traffic, and aggregate demographic data. We also link IP addresses to PII so that we can automatically fill out forms for you when you visit.
•We treat PII as our asset and Disclose it and other assets to third parties, including (without limitation) in sales, mergers, consolidations, changes of control, transfers of assets, reorganizations or liquidations and the like. TPGs or other TPMs may also consider the PII that they receive to be an asset that they own.
•We Disclose PII to anyone as required or as we think advisable (in our sole discretion) under applicable or potentially applicable laws (e.g., subpoenas and so on). We also Disclose it to verify with whom we or a TPM is dealing and to comply (voluntarily or involuntarily) with requests of governmental or law enforcement officials.
•Without undertaking a duty to do so, we may Disclose PII: to prevent economic or personal loss or damage to anyone (including ourselves) or to prevent fraud or unauthorized use of PII or the Site; or when we think Disclosure might help protect, defend or enforce rights and property of ours or anyone else.
It is impossible to list every lawful use that can be made of information and the above is not intended to do so. It is only a general description and we reserve all rights to make other lawful uses of PII.
Your Control Over Further Disclosures By Us
If you no longer want to receive emails from us or do not want us to continue providing PII to TPMs, you may click on the unsubscribe link contained within an e-mail message from us, or you may contact us via e-mail at Unsubscribe@ThinkAction.com or write us at Our Address for Legal Notices with a request to be unsubscribed. Unsubscription requests are usually processed within 72 hours and you may receive additional emails during this processing time. To stop receiving emails from a TPM to whom we Disclosed PII before you unsubscribed, you will need to follow their directions for unsubscribing -- unsubscribing from our list will not remove you from other lists. Unsubscribing does not result in deletion of your PII from our database. In normal practice we tend to delete PII about two years after it is first entered, but even after deletion, we retain some of it for administrative purposes (such as your name and when you first registered). Also, if we think retention of more PII is necessary or useful for some other reason; we reserve the right to retain it.
If you are a resident of California or another state with a law requiring us to provide the following information, once a year you may ask us to provide you with a list of: the standardized categories of information we disclosed to TPMs for their direct marketing purposes during the immediately preceding calendar year, and the names and addresses of those TPMs and the nature of their business, all as and if required. To request this information, write us at Our Address For Legal Notices.
Security. With respect to security of PII when it is in our database (your registration information, for example), we attempt to protect that PII from unauthorized access by taking several steps. For example, (i) we restrict access to PII to employees who need access in order for them to do their jobs. These employees are limited in number and we have privacy and security policies that apply to them; and (ii) the servers on which we store PII have physical and electronic security intended to create what we believe is commercially reasonable security. We do not encrypt stored or transmitted PII. Nevertheless, we do not guarantee security. Neither people nor security systems are foolproof, and people can make mistakes, commit intentional crimes, or fail to follow policies or contracts.
Your e-mails to us are not necessarily secure against interception so do not include sensitive information in them – we generally will not ask for sensitive information (such as passwords and financial account numbers) and you should assume that if you get such a request, it might be fraudulent.
You agree promptly to notify us via e-mail at webmaster@thinkaction.com if your password is lost, stolen or used without permission.
Your Consent to Electronic Notice If There is a Security Breach: If we are required to disclose or provide notice of unauthorized access to or other invasions of certain security systems, you agree that we may do so when required (and when we voluntarily wish to provide notice) by either posting notice on our Site or giving notice to any email address we have for you, in our good faith discretion.
Identity Theft. If any person believes they are a victim of identity theft entitled by law to request information from us, write us at Our Address For Legal Notices and we will explain what additional information must be provided to us. After we have received that information, we will supply (without charge) the information legally required to be disclosed that we then have, subject to applicable law and reserving all of our rights and defenses.
Links. This Site contains links to other sites, including sites of TPGs or others. The links are provided to connect you to TPGs or other TPMs or for your convenience – but we do not endorse those sites and have no liability for them (including without limitation, for their privacy policies or their products or services). Also, those sites (or the companies that run them) are not our partners or agents no matter what they say. Any dealings with a TPG or other TPM or solely with them, not us.
Your Ability to Update PII. Our business depends upon the accuracy, currency and reliability of your information, as does your ability to participate in some programs or surveys. In our Terms of Use, you also agree that if you provide information it will be accurate. To keep that promise and to improve your chances of participating in a wider range of opportunities, you agree to update your information as allowed on our Site. We do not maintain all PII in a form that can be updated and we may keep a record of changes (including deletions) and Disclose them for any lawful purpose. We may also determine what may be changed (e.g., if we are required to keep track of certain kinds of actions, you may not change relevant information).
Amendments. We will be changing what we do and how and why we Disclose data periodically – this Policy describes what we currently envision but that will change. You agree that we may amend all or part of this Policy from time to time in our discretion. You also agree that we may give notice of an amended version by posting notice on the Site's homepage thirty (30) days prior to the effective date of the amended version; or we may give notice by another method, including (without limitation) by email. You agree to check the home page periodically for notice of an amended version and to review that version. All amended versions will apply retroactively to all PII we have before and after the effective date (and until the next amended version takes effect). You agree that Using the site or accepting a TPM opportunity after the effective date of the amended version, or failing to unsubscribe by the effective date, will constitute your agreement to the amended version. If you do not want to agree to an amended version, make sure that you (i) unsubscribe before its effective date by sending an email to Unsubscribe@ThinkAction.com or writing us at Our Address for Legal Notices; and (ii) do not use the Site or accept an opportunity from a TPM after the effective date.
Information About Enforcement of Our Policy. This Policy is part of the Site Terms of Use. If there is an inconsistency between the Terms of Use and this Policy, the latest version of this Policy will control. As a contract, we and you are bound by this Policy. If you think we are in default, you may contact us by sending an e-mail to Our Address For Legal Notices. There are no third party beneficiaries of this Policy.