ROCKBRIDGE ASSOCIATES, INC.
Effective Date: October 2013
Last updated: June 30, 2020
Interpretation and Definitions
The words of which the initial letter is capitalized have meanings defined under the following conditions.
The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as You are the individual using the Service.
Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Rockbridge Associates, Inc.
For the purpose of the GDPR, the Company is the Data Controller.
- Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
- Account means a unique account created for You to access our Service or parts of our Service.
- Website refers to Rockbridge Website, accessible from http://rockresearch.com/.
- Service refers to the Rockbridge Website and any surveys or other marketing research response collection platforms in any format.
- Country refers to: Virginia, United States
- Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
- Third-party Social Media Service refers to any Website or any social network Website through which a User can log in or create an account to use the Service.
- Personal Data is any information that relates to an identified or identifiable individual. For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
- Cookies are small files that are placed on Your computer, mobile device or any other device by a Website, containing the details of Your browsing history on that Website among its many uses.
- Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
- Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
- Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across Websites.
- Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.
- Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
- Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal information to another business or a third party for monetary or other valuable consideration.
Collecting and Using Your Personal Data
Types of Data Collected
- Personal Data is any type of information, including information transferred from the EU or Switzerland to the United States, recorded in any form, that may be used to identify a specific individual. We may collect a variety of Personal Data from You, including but not limited to Your full name, non-governmental identification numbers, date of birth, gender, mailing address, phone numbers, email address and other similar information. We may also collect information about Your personal opinions and preferences.
- We may collect Personal Data from You directly when You voluntarily provide it to us (for example, through a contact form or on Opinion Pond) or We may obtain Personal Data from clients who ask us to conduct research on their behalf. We may also obtain Personal Data from list providers who have assured us that their lists are made up only of individuals who have given their permission to be included in the list.
- We may collect and use Personal Data obtained from publicly available sources, where this is permitted by law.
- We may occasionally collect Personal Data that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, genetic data, biometric data, trade union membership or that concerns an individual’s health (“Sensitive Data”). We will not collect such Sensitive Data without Your consent and will fully comply with all legal restrictions related to the collection, storage, use and transfer of such Sensitive Data.
- We will never ask You for certain information which, if stolen or misused, could give rise to economic crimes against You, such as bank account or credit card numbers, social security or other similar government-issued ID numbers.
- We may also automatically collect a variety of publicly available information, such as IP address and device ID, for system administration, service improvement and data integrity purposes.
- You may provide personal information to us when You contact us through Our Website seeking information about our services. We will treat this information as confidential Personal Data.
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit Our Service or when You access the Service by or through a mobile device.
TRACKING TECHNOLOGIES AND COOKIES
You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of Our Service.
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your Web browser. Learn more about cookies in the “What Are Cookies” article.
We use both session and persistent Cookies for the purposes set out below:
- Essential Cookies
- Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
- Functionality Cookies
- Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering Your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter Your preferences every time You use the Website.
- Performance Cookies
- Purpose: These cookies collect information about how You use a website, for instance which pages You go to most often, and if You get error messages from web pages.
- Marketing Cookies
- Purpose: These cookies are used to deliver advertisements more relevant to You and Your interests. They are also used to limit the number of times You see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that You have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the organization.
For more information about the cookies We use and Your choices regarding cookies, please visit our Cookies Policy at the bottom of http://rockresearch.com/.
Use of Your Personal Data
HOW WE SHARE YOUR INFORMATION
- To contact You about Our services: If You provide information to Us in order to inquire about Our services, We will only use that information to contact You about Our services. We will not sell or provide Your information to any third party for any other use. By submitting this Personal Data through Our Website contact form, You are consenting to sharing Your personal information within Rockbridge Associates. For more information about Rockbridge Associates, please see Our Website: http://rockresearch.com/.
- With Our employees: We may share Your Personal Data with employees of Our company for the purpose of analyzing survey responses.
- With field services: In some circumstances, in order to gain Your participation in Internet-based, telephone or in-person survey research, We may transfer Your name and email address or Your name and telephone number to a marketing research field service facility, to a professional interviewer located in Your home country, or to a company that operates Internet based research platforms such as ConfirmIt, Qualtrics, Medallia or QuestionPro. Before doing so We will ensure that the third party provides and agrees in writing to provide an adequate level of protection and will not use it for any other purpose.
- With incentive fulfillment companies: In some circumstances, with Your permission and where it is legal to do so, We may transfer Your name and email address to a fulfillment company in order to send You an e-gift card as a “thank You” incentive for participating in survey research. Before doing so We will ensure that the fulfillment company provides and agrees in writing to provide an adequate level of protection for Your personal information and will not use it for any other purpose. If You provide personal information in a survey or other research instrument to which You are responding, We will anonymize Your response and will not supply any information that could personally identify You to any other entity, including our clients, without Your permission.
- Where required by law: Rockbridge Associates may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
- With Website Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service.
- For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
- With other users: when You share personal information or otherwise interact in the public areas of Our qualitative research platform with other users, such information may be vieWed by all users and may be publicly distributed outside. Any time You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
HOW WE USE INFORMATION YOU PROVIDE
- The information collected in a research context may be used to plan new products or services, gauge customer/member satisfaction, measure awareness of products or services, or to test reaction to products, services or communications.
- Even if certain information is not considered Personal Data, We will protect the anonymity of Your responses to questionnaires, in focus groups, on research websites or from any means of collecting feedback from You in a research context. If We obtain Your contact information from a research panel or other third party, We will comply with the contact limitations and data protections that You agreed to when You signed up to participate in survey research or when You became a customer of a third party.
- We may occasionally re-contact You to validate Your participation in a research study; We will identify Ourselves and Our purpose when We conduct such validation contacts.
- Many research surveys include demographic questions collecting Sensitive Data such as racial or ethnic origin, age, gender or income. We use these questions to help Us make sure that the research reflects a representative sample of the population We are studying.
- If We receive Your contact information from a list or panel company, We will use it only in order to ask You to participate in marketing research, to conduct survey research with You, to validate answers You give, and to respond to Your requests to Us or Our client. We select panel companies that adhere to an opt-in process in obtaining panelists and have an adequate policy for protecting the privacy of panelists. We will also not use Your information in any other way that is inconsistent with the research or other purpose for which You agreed to be contacted.
- If We receive Your contact information from Our client and You are a customer of that client, We will only use Your contact information to ask You to participate in marketing research. We will not use this information to sell You any goods or services. We will protect Your anonymity when communicating Your research responses to clients unless You have explicitly given permission for Your identity and contact information to be shared with Our client or You have specifically asked Us to give that information to Our client so that they may resolve questions or complaints You may have.
- Whether We obtain Your Personal Data from a list company or from clients, We will not use this information to sell You any goods or services and We will not provide Your contact information to any other party so that they may use that contact information for the purpose of directly selling You goods or services. We will share Your Personal Data with Our clients only with Your specific permission or at Your request, or with restrictions as permitted by the Insights Association Code of Standards and Ethics for Marketing Research and Data Analytics.
- If We receive Your Personal Data from information You provided filling out the Contact Form on our Website, We will use that Data to respond to Your request for information. We may also use it to provide You with news and general information about services We offer that are similar to those that You have already purchased or inquired about unless You have opted not to receive such information.
- If We receive Your Personal Data from information You provided in order to exercise Your data privacy rights, We will use that Data only to respond to and manage any of Your requests to Us.
LEGAL BASES FOR PROCESSING
We may process Your Personal Data where You have given Your consent to such processing for one or more specific purposes, where processing is necessary for complying with Our legal obligations, where necessary to protect Your vital interests or those of another natural person, or where necessary for the purposes of the legitimate interests pursued by Rockbridge or by a third party, except where such interests are overridden by Your interests or fundamental rights and freedoms. Where processing is based on Your consent, You have the right to withdraw consent at any time; however, this will not affect the lawfulness of processing based on consent before its withdrawal.
Retention of Your Personal Data
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Disclosure of Your Personal Data
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
OTHER LEGAL REQUIREMENTS
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
Detailed Information on the Processing of Your Personal Data
Third-Party Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service providers to monitor and analyze the use of our Websites.
Google Analytics is a Web analytics service offered by Google that tracks and reports Website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms Web page: https://policies.google.com/privacy?hl=en
If You submitted Your Personal Data requesting information about Our services, We may contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
- Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
- Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
- Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
- Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
- Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
- Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
- Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, You can access, update or request deletion of Your Personal Data directly within Your account settings section. If You are unable to perform these actions Yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
- Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
- Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation that makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
- Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
- Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
- Withdraw Your consent. You have the right to withdraw Your consent on using Your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
Exercising Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that We may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.
Rockbridge Participation in EU-U.S. and Swiss-U.S. Privacy Shield Program
PRIVACY SHIELD PRINCIPLES
Accountability for Onward Transfers
We will ensure that any third party to which Personal Data may be disclosed subscribes to the Principles and agrees in writing to provide an adequate level of privacy protection. Pursuant to the Privacy Shield Principles, Rockbridge Associates may face potential liability in cases of improper transfers of Privacy Shield data to third parties.
We take reasonable steps to protect Your Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction. We have put in place appropriate physical, electronic and managerial procedures to safeguard and secure Your Personal Data from loss, misuse, unauthorized access or disclosure, alteration or destruction, but We cannot guarantee the security of information on or transmitted via the Internet.
Data Integrity and Purpose Limitation
We will only process Personal Data in a way that is compatible with and relevant to the purpose for which it was collected or authorized by You. To the extent necessary for those purposes, We will take reasonable steps to ensure that Your Personal Data is accurate, complete, current and reliable for its intended use. We will limit use of Your Personal Data to the use We disclosed to You when We collected it. Prior to using any Personal Data for another purpose We will notify You and obtain Your permission.
Recourse, Enforcement and Liability
- By email: email@example.com
- By mail:
Rockbridge Associates, Inc.
10130-G Colvin Run Road
Great Falls, VA 22066
- Toll-Free By Phone: 1-800-765-0084
Further Recourse for European and Swiss Individuals:
Rockbridge Associates has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If You do not receive timely acknowledgment of Your complaint, or if Your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. This dispute resolution process will be free of charge to You.
Under certain limited conditions, an individual may invoke “last resort” binding arbitration.
Your Rights under the CCPA
- 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.
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)
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.
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
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 below.
- By email: firstname.lastname@example.org
- By mail:
Rockbridge Associates, Inc.
10130-G Colvin Run Road
Great Falls, VA 22066
- Toll-Free By Phone: 1-800-765-0084
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.
Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Links to Other Websites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
- By email: email@example.com
- By mail:
Rockbridge Associates, Inc.
10130-G Colvin Run Road
Great Falls, VA 22066
- Toll-Free By Phone: 1-800-765-0084