1:1 Corporation collects and analyzes responses from online interviews, questionnaires or surveys ("Interviews") on behalf of 1:1 Corporation clients ("Clients"). Respondents may be employees, customers or other persons who consent to be contacted or who have pre-existing relationships with the Client for whom we are collecting the data ("Respondents"). As described in this Section I, we do not own the Personal Data that we process. "Personal Data" means information relating to an identified or identifiable person.
1. 1:1 Corporation IS A DATA PROCESSOR
1:1 Corporation processes, on behalf of its Clients, Personal Data that has been collected by or on behalf of those Clients. Using the definitions in the United States/European Union Data Protection Safe Harbor Arrangement (the "Safe Harbor")*, 1:1 Corporation acts as a Data Processor and each 1:1 Corporation Client acts as a Data Controller. 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 is processed. To "process" Personal Data means to carry out 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 applies; for example, the person who participates in an Interview.
2. CLIENT INSTRUCTIONS
As a Data Processor, 1:1 Corporation will only process Personal Data in accordance with the instructions of the applicable Client. 1:1 Corporation 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 foregoing and subject to the limitations noted in Section III below, 1:1 Corporation will not transfer Personal Data to a third party (which, for purposes of this Privacy Statement, means an entity other than 1:1 Corporation and its applicable Client) without instructions from the applicable Client. 1:1 Corporation 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, 1:1 Corporation will not provide a purported Data Subject with access to his or her Personal Data unless it is demonstrated to 1:1 Corporation's satisfaction that the applicable Data Controller has refused such access.
3. PERSONAL DATA COLLECTION
Interviews are initiated to improve the processes and relationships between our Clients and their customers or other entities, or to improve the Client's internal business operations. Typically a Client's customers provide the Client with certain information including their names, companies, job titles, phone numbers, and email addresses. The Client may also collect similar information from its employees or from other persons with whom the Client has a business relationship. The Client provides such information to 1:1 Corporation to enable us to process and analyze Interviews on behalf of the Client. In addition, commercial list services may provide 1:1 Corporation with contact information for people who have opted to receive email ("opt-in lists") on specific topics of interest.
We invite potential Respondents (by email as well as other media) to participate in Interviews hosted on 1:1 Corporation's site(s) (e.g., 1to1corp.com or any successor web sites) or hosted at third party survey processing sites used by 1:1 Corporation for this purpose (e.g.confirmit.com). When a Respondent chooses to participate, our web site servers (which may be hosted by a third party service provider) may also collect information indirectly and automatically (through, for example, the use of "cookies" or the Respondent "IP address") about the Respondent activities on the site(s). 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.
Cookies are small pieces of information stored on Respondent's hard drive, not on our site(s). Cookies allow us to better understand how Respondents use the site(s), which in turn helps us focus our resources on improvements to the site(s). We may use session cookies, which expire when the browser window is closed, and persistent cookies to keep track of which Interviews a particular Respondent has completed. A Respondent may decline our cookies (if his browser permits), but in that case, the Interview site(s) may not operate properly. An IP address is a number that is automatically assigned to a computer 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.
In some cases, we use unique identifiers in email messages, which enable us to determine which emails have generated responses, or which permit individualized access to an Interview. This allows us to assess the effectiveness of our communications and to exclude those persons who have already responded to a certain message from duplicate messages. This also allows us to merge other data with the Interview response, for example the Respondent list provided by the Client may indicate the type of product owned by that Respondent, geographic region, job function, etc. Such merged data would then permit analysis of results according to type of product, geographic region, job function, etc.
Interview Respondents may be required to submit information such as a phone number, email address, or postal mail address in order receive a gift or other incentive offering (if applicable).
In the email Interview invitations we send, we provide an opportunity for recipients to 'opt-out' of receiving future email survey invitations on behalf of the applicable Client. We will provide the "opt-out" list to our Client, and it is the Client's responsibility to properly update the Client's lists.
4. PRESERVATION OF INDIVIDUAL RESPONDENT PRIVACY ON BEHALF OF CLIENTS
In order to encourage Respondents to more freely provide information which accurately reflects what they believe, 1:1 Corporation may filter personally identifying information from the data we provide to Clients, for example the Respondent's name, phone number, email address or other unique identifiers. If such filtering is to be performed, the invitation to respond to an Interview will contain an indication that the response is "Confidential" or some similar indication ("Confidential Interview"). The Client remains the Data Controller of all Personal Data, however on Client's behalf we will hold this unique identifying information from any Confidential Interview response, in order to allow the Client to make a privacy commitment to Respondents regarding such Confidential Interviews.
1:1 Corporation can not guarantee that advanced statistical processing and data correlation methods could not uncover other ways to personally identify Interview responses. When we conduct Confidential Interviews, we take reasonable technical and operational measures to reduce the possibility of such personal identification, however ultimately the responsibility to adhere to a Client's stated privacy commitment rests with the Client.
In most Interviews, Respondents have the ability to provide free format textual responses at some point(s) in the Interview. Like all other responses, these will be provided to our Client without any additional attached personally identifying information. However, a Respondent may choose to write a text response in which the text itself could provide clues to the Respondent's identity. If a Respondent to a Confidential Interview wishes to remain confidential, the Respondent must not disclose personally identifiable information in such textual responses.
Even if an Interview is identified as a Confidential Interview, unless explicitly stated otherwise, 1:1 Corporation may provide to the Client a list of which individuals completed, did not complete, or partially completed an Interview. If gifts or other incentives have been offered to encourage responses, 1:1 Corporation may provide identification of the individuals who are to receive the gifts or incentive offerings, along with any information necessary to deliver or fulfill the gifts or incentives.
5. USE OF COMPARATIVE DATA
1:1 Corporation provides services to its Clients in which 1:1 Corporation analyzes a Client's Interview data in comparison with that of other organizations ("Comparative Analysis"). However, 1:1 Corporation does not process any Personal Data in performing Comparative Analysis. 1:1 Corporation 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 Comparative Analysis, and 1:1 Corporation discloses only non-Personal Data in aggregate form ("Comparative Data") to its Clients who have requested Comparative Analysis.
In addition to the data we process on behalf of our Clients, 1:1 Corporation also processes (on its own behalf) information about our Clients and the individuals who represent our Clients.
1. COLLECTION AND USE OF BUSINESS
The individuals who represent 1:1 Corporation's Clients, potential Clients, or vendors ("Business Contacts") may voluntarily provide their contact information and related data (collectively "Business Contact Data") to 1:1 Corporation by various means, including telephone, email, postal mail, "contact us" or "download" pages on the 1:1 Corporation web site(s), or other means. The Business Contact Data submitted to 1:1 Corporation is used to communicate with and provide services for Clients and potential Clients. 1:1 Corporation corrects or updates Business Contact Data when a request by the applicable Business Contact is emailed to or mailed to 1:1 Corporation, 1057 Montague Expy., Milpitas, CA 95035, USA.
When a Business Contact accesses reports through 1:1 Corporation's servers, or otherwise uses the 1:1 Corporation site(s), 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 assess the effectiveness of our 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 information packages. We provide a way to opt-out of our newsletter and other promotional communications. Users may opt-out by following instructions included in these communications or by contacting .
In addition to Business Contact Data, 1:1 Corporation may collect non-personally identifiable information indirectly and automatically about visitors' use of the site(s), including the sequence of web pages viewed on the site(s), the web page from which the visitor linked to the site, the web page to which the visitor linked from the site, and information about the browser the visitor is using. 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
Generally, 1:1 Corporation does not provide Business Contact Data or other data to third parties. 1:1 Corporation may provide Business Contact Data or other data to third parties to the extent such third parties provide operational assistance (i.e., outsourced or third party services) to 1:1 Corporation and then only for that purpose. 1:1 Corporation may share Business Contact Data or other data with its corporate family, including its parent company, subsidiaries, or other companies under common control with 1:1 Corporation for the same operational assistance.
1. SECURITY MEASURES
1:1 Corporation uses common industry security 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. 1:1 Corporation limits access to Business Contact Data or Personal Data to those persons in 1:1 Corporation's organization who have a business need to process such Business Contact Data or Personal Data. However, no company, including 1:1 Corporation, can fully eliminate the security risks associated with such Business Contact Data or Personal Data.
Due to factors beyond 1:1 Corporation's control, 1:1 Corporation cannot ensure that Business Contact Data or Personal Data will not be disclosed to third parties. For example, 1:1 Corporation may become legally obligated to disclose such data, or, despite precautions, third parties may circumvent security measures to intercept or access such data.
Notwithstanding anything else in the Privacy Statement, 1:1 Corporation reserves the right to utilize any data in our possession, including making disclosures to third parties, to the maximum extent permitted by applicable law, in order to prevent the commission of a crime or other violation of law, to counteract attempts to bypass system security measures, or to prevent any other damage, theft or injury.
3. CORPORATE FAMILY AND
If another company acquires 1:1 Corporation or substantially all of its assets, that company will (a) succeed to ownership of the Business Contact Data held by 1:1 Corporation and will possess the Personal Data held by 1:1 Corporation, and (b) assume the rights and obligations regarding such Business Contact Data and Personal Data described in this Privacy Statement.
Questions, comments, or complaints about this Privacy Statement or 1:1 Corporation's data practices may be emailed to or mailed to 1:1 Corporation, 1057 Montague Expressway, Milpitas, CA 95035, USA.
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 1:1 Corporation Client for whom 1:1 Corporation processes data, should be directed to that Client.
5. CHANGES TO POLICY
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* Note: 1:1 Corporation is not yet certified under the Safe Harbor. The publication of this Privacy Statement is a necessary step towards that end. Nevertheless, to the best of our knowledge and belief, our data procedures are adequate to meet the requirements of the Safe Harbor. To expedite dispute resolution regarding Personal Data for any individual Data Subject, upon properly documented request of that individual and at no charge, we will expunge all Personal Data for that Data Subject from any data systems that we operate or control. A properly documented request only requires (1) reliable identification of the requesting Data Subject, and (2) the Data Subject's statement of why he or she believes the Personal Data has not been handled appropriately.