PRIVACY NOTICE
Last updated: September 20, 2024
Previous version of Privacy Policy
Escalent, Inc., formerly known as Market Strategies International-Morpace, and its affiliates, including Communispace Corporation d/b/a C Space, Promise Corporation Limited t/a C Space, Hall & Partners USA LLC, and Hall & Partners Europe Ltd (collectively, “Escalent”, “we”, “our” or “us”) is a leading provider of online market research projects on behalf of our clients (“Sponsors”). We are committed to protecting the privacy of our Sponsors and research participants (collectively, “you”). This privacy policy explains how we process your personal data in connection with our business, including the provision of our websites, including https://escalent.co/, www.hallandpartners.com, and www.cspace.com (collectively, our “Sites”) and/or through conducting our market research services (the “Services”). Anyone who has access to such information or data must follow this privacy policy.
This privacy policy only applies to our use of your personal data, whether obtained directly from you or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links on our Site to third party websites over which we have no control). Further, this privacy policy is not intended to cover the processing of workplace personal data. Accordingly, if you are engaged as a worker for us, please see our Workplace Privacy Notice which sets out further information about how we may process your personal data in connection with your employment and/or engagement.
This privacy policy is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand this Privacy Notice. It is intended to be read in conjunction with our Terms of Use and Cookie Notice.
1.PERSONAL DATA WE PROCESS
When we talk about personal data we mean any information which relates to an identified or identifiableliving individual. In the last twelve months, we have collected the following types of personal data, in thefollowing ways, for the following purposes:
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Category of Personal Data and Specific Examples |
Purpose of Collection |
Legal Basis |
Third Parties With Whom We May Share |
Retention Period |
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When you visit our Sites |
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Identifiers and Professional or Employment-Related Information when you send us an inquiry.
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To respond to inquiries you send through the Site |
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. |
With our trusted vendors and service providers acting on our behalf. |
See “HOW WE STORE AND SECURE YOUR PERSONAL DATA”
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Identifiers and Professional or Employment-Related Information when you subscribe to our newsletter.
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To provide you with email updates and marketing communications from us about our services, such as newsletters or email
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Consent Legitimate interest (e.g., essential cookies). |
With our trusted vendors and service providers acting on our behalf. |
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Identifiers and Internet or other similar network activity through your interactions with our Sites.
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For marketing, analytics and statistics purposes. |
Consent. Legitimate interest (e.g., essential cookies).
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With our trusted vendors and service providers acting on our behalf.
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When you interact with our Services |
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Identifiers when you apply to participate or choose to participate as a research participant for our Services:
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To conduct market research on behalf of our Sponsor, including to determine whether you meet the criteria to participate in our Services. |
Consent. 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. |
With the Sponsor. With our trusted vendors and service providers acting on our behalf. |
See “HOW WE STORE AND SECURE YOUR PERSONAL DATA” |
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Identifiers and Internet or other similar network activity through your interactions with our Sites.
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To analyze, evaluate and/or improve our Sites, Services and/or market research tools. |
Consent.
Legitimate interest (e.g., essential cookies). |
With our trusted vendors and service providers acting on our behalf. |
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Sensitive data when you apply to participate or choose to participate as a research participant for our Services:
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To conduct market research on behalf of our Sponsor, including to determine whether you meet the criteria to participate in our Services. |
Consent. Such information is not collected for any discriminatory purposes. You will always retain the right not to answer any question with which you do not feel comfortable. |
With the Sponsor. With our trusted vendors and service providers acting on our behalf. |
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We may process your personal data using artificial intelligence-based software solutions and technologies consistent with this Privacy Notice.
We will not sell the personal data we collect. We also will not share it with third parties for cross-context behavioral advertising.
Please read our Cookies Notice for more information about the type of cookies and tracking technologies we use on this website, the reasons for their use, and information on how to accept and reject the cookies and tracking technologies.
2. ADDITIONAL WAYS WE MAY SHARE YOUR PERSONAL DATA
In addition to the sharing discussed above, we may also share your information in the following ways:
(a) as reasonably necessary to comply with law or a legal process (including a court or government order or subpoena), to detect, prevent, or otherwise address fraud, security or technical issues, to enforce this privacy policy, and to protect the rights, property or safety of Escalent, our users, and/or the public;
(b) if we sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a corporate transaction such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this privacy policy; or
(c) with your express consent.
If you participate as a research participant in our Services, we may share your information with the Sponsor for whom the market research is conducted. In most cases, your information is shared with Sponsor only on an aggregate and anonymous basis. In some cases, however, Escalent may share your personal data with the Sponsor, or the Sponsor may have access to that information in the Services. In these circumstances, your personal data may be handled in accordance with the Sponsor’s privacy policy, a copy of which will be made available through your use of the Services, but the Sponsor’s use of your information will also be consistent with the purposes set forth above.
3. SOURCES OF PERSONAL INFORMATION
Depending on how you interact with our Site and Services, we may collect your personal data from a variety of sources, including:
4. HOW WE STORE AND SECURE YOUR PERSONAL DATA
In general, we will only retain your information for the time necessary to realize our legitimate business purposes and to comply with the law. However, we may continue to store anonymous or anonymized information, such as Site visits, without identifiers, in order to improve our services. If any personal data is only useful for a short period (e.g. for a specific event or marketing campaign or in relation to recruitment), we will delete it at the end of that period. Please note that if you are an unsuccessful candidate we may keep your information for a short period.
Escalent takes reasonable and appropriate measures to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal data.
5. DATA TRANSFERS OF EUROPEAN, UNITED KINGDOM, AND SWISS PERSONAL DATA
To the extent our processing of your personal data is caught by the requirements of the United Kingdom (UK) GDPR and/or GDPR, when transferring your personal data to territories outside the UK or the EEA, we will ensure that, where required by applicable law, at least one of the following safeguards is implemented: (1) we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the Swiss Government, and UK Government, and the European Commission; or (2) where we use certain service providers, we may use specific contracts approved by the Swiss Government, and UK Government, and the European Commission (EC) referred to as the “Standard Contractual Clauses” or “SCCs” which give personal data the same protection it has in Switzerland, the UK and EU. To find out more about the SCCs we use, please see: Standard contractual clauses for international transfers | European Commission (europa.eu) or please contact us.
Escalent complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Escalent has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Escalent has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. Escalent remains responsible for any of your personal information that is shared under the Accountability for Onward Transfer Principle with third parties for external processing on our behalf, as described in the “How We Share Your Personal Data” section. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
Escalent has mechanisms in place designed to help assure compliance with the DPF Principles. Hall & Partners conducts an annual self-assessment of its Consumer Personal Data practices to verify that the attestations and assertions Hall & Partners makes about its Data Privacy Framework privacy practices are true and that Hall & Partners’ privacy practices have been implemented as represented and in accordance with the DPF Principles.
Consumers may file a complaint concerning Escalent's processing of their personal data by contacting us at the email address provided in the “Contact Us” section at the end of this privacy policy. Escalent will take steps to remedy issues arising out of its alleged failure to comply with the DPF Principles.
If a consumer’s complaint cannot be resolved through Escalent’s internal processes, Escalent will cooperate with JAMS pursuant to the JAMS International Mediation Rules, available on the JAMS website at www.jamsadr.com/international-mediation-rules. JAMS mediation may be commenced as provided for in the relevant JAMS rules. The mediator may propose any appropriate remedy, such as deletion of the relevant personal data, publicity for findings of noncompliance, payment of compensation for losses incurred as a result of noncompliance, or cessation of processing of the personal data of the consumer who brought the complaint. The mediator or the consumer also may refer the matter to the U.S. Federal Trade Commission, which has Data Privacy Framework investigatory and enforcement powers over Escalent. Under certain circumstances, consumers also may be able to invoke binding arbitration to address complaints about Escalent’s compliance with the DPF Principles.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Escalent commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.
6. DO NOT TRACK SIGNALS
We do not monitor or follow “Do Not Track” (DNT) signals because there is no standard interpretation or practice for DNT signals. Therefore, we handle all user information consistent with this privacy policy. We will never use browsing activity information from our survey respondents or other website visitors to provide or offer third party advertising content. We will treat any “do not sell” or similar signals as opt-out requests under CCPA.
7. COUNTRY-SPECIFIC DATA PROTECTION PROVISIONS
Provisions for Individuals in the People’s Republic of China
For studies involving citizens of the People’s Republic of China (PRC) or other individuals covered by the Personal Information Protection Law (PIPL), client contact lists or other personal data will only be processed in accordance with the parameters described in our Notice to PRC Residents.
Provisions for Individuals in South Africa
If you are accessing our services from South Africa, please review our POPIA Privacy Notice to understand how we process your personal information in accordance with the Protection of Personal Information Act, 2013 (POPIA).
8. CHILDREN’S PERSONAL DATA
Our Sites are not intended for use by children, particularly those under age 16, and we do not knowingly collect information from children. In the event that we learn that we have collected personal data on the Site from a child under age 16, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 16, please contact us at the email provided in the “Contact Us” section at the bottom of this privacy policy. We do, however, collect information about children under the age of 16 from their parents/guardians through some of our Services. We ask that our users do not provide information about a child without first obtaining consent from the child’s parents/guardians. Where appropriate, we will always ask for consent from a parent or guardian to collect information about children. In the event that we learn we have collected any personal data from a child under the age of 16 through the provision of our Services without verification of parental consent, we will delete that information from our database as quickly as possible.
9. YOUR RIGHTS AND CHOICES
Depending on where you live and subject to certain exceptions, you may have some or all of the following rights:
You may exercise these rights in writing using our contact information provided in this privacy policy or via this web form.
California residents, or residents of another state which grants you similar rights, may exercise these rights by contacting us at (877) 631-3505 or by filling out this webform link. If you are a resident of California, Colorado, Connecticut, Oregon, Montana, and Texas, you may, under certain circumstances, authorize another individual or a business, called an authorized agent, to make requests on your behalf. We may ask you to provide additional information in order to verify who is making the request. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have. We will endeavor to promptly respond to your requests. Where you ask us to provide a copy of your personal data we are legally obliged to respond within one month of such request. If your request is denied, we will inform you about the reasons for denial. Residents of Colorado, Connecticut, Oregon, Montana, Texas, and Virginia have the right to appeal a denial of their request by contacting us as described in the notice of denial.
Please note that any requested disclosures may only apply to the 12-month period preceding the request, depending on how difficult it is for us to retrieve the necessary information, and you are entitled to request disclosure regarding your personal information twice in any 12-month period.
Nevada Residents. Residents of the State of Nevada have the right to opt-out of the sale of certain pieces of their information to third parties. Currently, we do not engage in such sales. If you are a Nevada resident and would like more information about our data sharing practices, please contact us.
California “Shine the Light Law”. California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their own direct marketing purposes in the preceding calendar year. To make such a request, please contact us.
10. THIRD-PARTY LINKS AND SERVICES
Our Sites and Services contains links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this privacy policy no longer applies to these third-party websites and third-party service providers unless we are acting as joint controllers in respect of your personal data with such third party.
Your browsing and interaction on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.
Our Sites and Services may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Sites and Services, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.
To help facilitate login to our communities, we may offer a sign-on option to our Services using login credentials from your Facebook® account. This allows you to associate your existing Facebook® profile with your Escalent account. By linking these accounts, Escalent will have access to certain profile information contained within your Facebook® profile such as your full name, email, locale, gender, profile picture, as well as other publicly available profile information. No content shared through your participation in our Services will ever be shared on Facebook® without your express permission. You can disassociate your Facebook® account from your Escalent account at any time by clicking “Unlink” on your Member Profile page.
11. ACCESSING SERVICES THROUGH OUR MOBILE APPLICATIONS
You may have the option to access some of our Services through mobile applications we offer (collectively, our “Apps”). Use of our Apps is voluntary and optional. If you choose to use our Apps, you must provide login and password to access and complete the activities. The Apps may request your permission to collect location data and/or may request access to multimedia stored on your mobile device (i.e. photos or videos). Location data is not required for participation in market research activities; if you do not wish for your location data to be submitted, please respond accordingly when prompted on your mobile device. Multimedia will only be collected from your device if you affirmatively select it for submission through the application (i.e. you chose an image or video to submit for a market research activity). You can change your permissions with respect to location data and multimedia sharing through the settings feature on your mobile device. Any information and content collected through the Apps will be used consistent with this privacy policy and the policies and agreements applicable to your participation in our Services.
Use of the Apps may not be available for all Services, at the Sponsor’s discretion.
12. CHANGES TO THIS PRIVACY POLICY
We reserve the right to modify this privacy policy at any time. If we decide to change our policy, we will prominently post those changes here and any other place we deem appropriate, so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make any material changes, we will notify you and you will have the opportunity to review the revised policy before you choose to continue using our Site or Services (as applicable). We will use information in accordance with the policy as it was in effect at the time information was collected.
13. CONTACT US
To contact Escalent with questions or concerns about this privacy policy or Escalent’s personal data practices: