Privacy Statement

Concerning participation in Smarty Pants research projects and inclusion in the Smarty Pants research panel, also known as Smarty Pants Circle.

Smarty Pants, LLC, hereafter called Smarty Pants, conducts marketing research with participants who may complete research projects to provide feedback and opinions on a range of lifestyle, advertising and other questions, and may contribute other types of data along with other Research Participants. Active Research Participants receive certain benefits from Smarty Pants in exchange for participating in surveys.

1) OUR PRIVACY COMMITMENTS

Smarty Pants respects and protects the privacy of every Research Participant and Smarty Pants Circle panel member (Panel Member) and observes all domestic and international privacy laws and best practices, including the EU/EEA General Data Protection Regulation, to ensure the safety of any information provided by its Research Participants and Panel Members.

Smarty Pants complies with the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss/US Data Privacy Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom and/or Switzerland, as applicable to the United States. Smarty Pants has certified to the Department of Commerce that it adheres to the Insights Association Data Privacy Framework Services Program Principles with respect to such information. Smarty Pants adheres to the DPF Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the terms in this privacy policy and the DPF Principles, the DPF Principles shall govern. To learn more about the Insights Association Data Privacy Framework Services Program, and to view our certification, please visit www.dataprivacyframework.gov.

As we adhere to the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF and being subject to the investigatory and enforcement powers of the FTC, Smarty Pants commits to resolve complaints about your privacy and our collection or use of your personal information. European Union and Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Smarty Pants at:
Terrance Kennedy Tyree, Privacy and Compliance Manager for Smarty Pants, at 203-847-5766 or Privacy@asksmartypants.com.

Smarty Pants has further committed to refer unresolved privacy complaints under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF to the Insights Association DPF Services Program, a non-profit alternative dispute resolution provider located in the United States and operated by the Insights Association. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.insightsassociation.org/Resources/Data-Privacy-Framework/Information-for-EU-Swiss-Citizens-to-file-a-complaint for more information and to file a complaint. These dispute resolution services are provided at no cost to you.

In some limited circumstances, individuals may invoke binding arbitration before the Insights Association Data Privacy Framework Services Program Arbitration Panel. Dispute resolution facilitated by the International Centre for Dispute Resolution/American Arbitration Association (ICDR/AAA).

This Privacy Statement outlines the information Smarty Pants will collect and how we will use that information. This Statement will also tell you how you can verify the accuracy of your Personal Information (defined below) submitted to Smarty Pants and how you can request that we delete or update your Personal Information.

This Privacy Statement is intended to describe the ways that we implement the principles of our Privacy Policy for Domestic and Global Information in connection with our research projects and other research activities. We’ve developed this privacy statement from industry guidelines and standards, and local, national, and international laws and requirements. All privacy practices and methods described in this statement apply only insofar as permitted by the applicable standards, laws and requirements. In addition, as a member of the Insights Association, the professional trade association of marketing and survey research companies, Smarty Pants adheres to the mandated Insights Association Code of Standards and Ethics for Market Research and Data Analytics. You may visit the Insights Association and view the Code, at https://www.insightsassociation.org/Resources/Code-of-Standards.

2) INFORMATION COLLECTED AND HOW WE USE IT

WHAT WE COLLECT:

A) PERSONAL AND DEMOGRAPHIC INFORMATION

During the Smarty Pants recruitment process, Smarty Pants may collect personal information such as your name, address, and the names and ages of members of your household (“Personal Information”). In addition, Smarty Pants frequently asks Research Participants and Panel Members for characteristics (such as health problems or consumer habits), attributes, and demographic information (such as age, income, gender) (collectively, “Demographic Information”).

Smarty Pants only collects personal data that is relevant for the purposes of specific research projects or Panel maintenance. Smarty Pants takes reasonable steps to ensure that personal data is reliable for its intended use and is accurate, complete and current.

You are in control of the Personal Information and Demographic Information that you provide to Smarty Pants. We rely on you to provide updates to your Personal Information and Demographic Information. To access, correct or delete your data, please contact Privacy@asksmartypants.com.

You can:

Ask for a copy of your Personal Information or Demographic Information.
Ask for your Personal Information or Demographic Information to be corrected or updated.
Ask us to remove your Personal Information or Demographic Information from our records.

B) OPERATING INFORMATION

Smarty Pants may, in the course of interacting with Research Participants and Smarty Pants Circle panel members, gather other types of information from participants (“Operating Information”). For example, as a Smarty Pants Circle panel member, you may receive project participation requests from Smarty Pants from time to time. These requests will ask questions about your interests, needs, and attitudes and used to match you with specific research projects. We will receive your responses to these requests. Similarly, if we offer other features, services, or programs in which you explicitly agree to participate, then Smarty Pants will receive information from those features, services, or programs.

HOW WE USE YOUR INFORMATION:

A) PERSONAL AND DEMOGRAPHIC INFORMATION

Personal Information may be used to set up e-mail accounts for each household member who is 13 years of age or older, to communicate with you and your household members, and to assist you with questions that you may have about the Smarty Pants project or panel. It may also be used for panel recruitment, contest entry processing or delivery of gifts and incentives to Research Participants or members of the Smarty Pants Circle panel. Personal Information concerning location or address is also used to ensure that our panel accurately represents the country’s population as a whole.

Panel Members and Research Participants are asked for Demographic Information in order to pre-qualify members or households for research projects that target specific groups.

Smarty Pants uses Personal Information and Demographic Information solely in the conduct of its research business. Personal Information or Demographic Information may be combined with information collected about you by Smarty Pants or third parties with your express permission, with information that is collected about you from public records, or with information that Smarty Pants may acquire from third parties that have a legal right to provide such information to Smarty Pants.

B) OPERATING INFORMATION

Smarty Pants uses Operating Information solely in the conduct of its research business. As is the case with Personal Information and Demographic Information, Operating Information may be combined with information collected about you by third parties, such as research recruiting firms who have a legal right to provide such information with your express permission, or with information that is collected about you from public records.

3) DATA SHARING AND TRANSFER

A) HOW WE MAY SHARE INFORMATION:

Personal Information regarding Research Participants and Panel Members will never be shared with any third parties without your express permission, except that we may disclose your information if we believe we are required to do so based on a lawful request by public authorities, including to meet national security or law enforcement requirements. In addition, occasionally Smarty Pants will share contact information, such as name and address, with third parties with whom we have partnered to provide specific services to Smarty Pants, or services on behalf of Smarty Pants, such as panel recruitment, contest entry processing or delivery of gifts or incentives to Smarty Pants Research Participants and Panel Members. These partners are required to meet the same standards of privacy protection and have certified that they meet or exceed all lawful requirements including General Data Protection Regulations of the EU. In adhering to the Insights Association Data Privacy Framework Services Program, we may remain liable in some cases of onward transfer to 3^rd parties.

Smarty Pants collects and shares Demographic Information and Operating Information with its research clients. Our research clients will only receive Personal Information of Research Participants or Panel Members if you give specific consent for us to share with that Client. If your permission is granted to share Personal Data with a 3^rd party, Smarty Pants will only supply to a company who can certify that they are compliant with all privacy laws including General Data Protection Regulations of the EU.

B) DATA STORAGE:

Your Personal Information, Demographic Information, and Operating Information will be stored in our Research Company databases, which are located in the United States. This information lives in a password protected, secure environment and is only accessible by certain Smarty Pants employees who have a need to process the information for the intended purpose of the research we are conducting and that you have agreed to participate in.

4) CHILDREN’S PRIVACY

Smarty Pants believes that it is especially important to protect children’s privacy online and encourages parents and guardians to spend time online with their children to participate and monitor their Internet activity.

Smarty Pants complies with all applicable national and international children’s privacy regulations.

We comply with the Children’s Online Privacy Protection Act of 1998. We do not permit children who are under 13 years of age to become Smarty Pants Circle panel members. We do not collect any Personal Information from children under 13 years of age except as part of the registration process for new Panel Members. We collect from the new Panel Member the names of each individual in the Panel Members’ household, which may include the names of children who are under 13 years of age. Occasionally we may send a research participation request to a Panel Member who is a parent or guardian of a child under the age of 13 that asks if that Panel Member would be interested in having his or her child who is under 13 participate in a research project. We take reasonable steps to ensure parental consent to such procedure by sending the request to the parent or guardian’s password-protected email address. The information collected in response to such surveys is not combined with identifying information about the child. In every case such participation request does not collect Personal Information about the child.

Smarty Pants will require Verifiable Parental Consent for any project in which you agree to allow your child under 13 years of age to participate. A separate agreement describing the project and handling of your child’s responses and Personal Information will be provided for review and consent.

If you would like to contact us about your or your child’s Personal Information, or to find out how you can have your child’s Personal Information removed from our database, please see the “Choice and Opting Out” section later in this document.

5) DATA SECURITY AND RESPONSIBILITY

Smarty Pants is committed to keeping the data you provide us secure and will take all necessary precautions to protect your Personal Information from loss, misuse or alteration. Vendors, contractors, or partners of Smarty Pants who have access to your Personal Information in connection with providing services for Smarty Pants are contractually required to keep the information confidential and are not permitted to use this information for any other purpose than to carry out the services they are performing for Smarty Pants. Smarty Pants will also require any vendor, contractor or partner that we share your personal data with to be compliant with all local, state and federal laws of the US and EU including the General Data Protection Regulation for EU citizens.

Smarty Pants also safeguards Personal Information, Demographic Information, and Operating Information from unauthorized access. Only authorized Smarty Pants employees or agents carrying out permitted business functions are allowed to access these databases. In addition, each employee of Smarty Pants is required to sign a confidentiality agreement requiring him or her to keep confidential all Personal Information of Research Participants and Panel Members. Employees who violate the confidentiality agreement are subject to disciplinary actions, including termination when appropriate.

6) CHOICE AND OPTING OUT

Smarty Pants, LLC recognizes that participation in any research activity must remain entirely voluntary and that each Research Participant (or, in the case of minors, the participant’s parent or legal guardian) is entitled to direct how personal data is used or shared. Accordingly, you may, at any time and without penalty, exercise the following options:

Limit disclosure – instruct us not to disclose your personal data to any third party that is not acting solely as our agent or service provider.
Limit new purposes – instruct us not to use your personal data for any purpose materially different from the purpose for which it was originally collected or later authorized by you.
Pause or withdraw participation – decline to answer any question, exit a particular research project or request, or withdraw yourself (or your child) from the Smarty Pants Circle panel altogether.
Request correction or deletion – ask us to correct inaccurate personal, demographic, or operating information, or to delete such information when it is no longer required for the research purpose for which it was obtained.

To exercise any of these choices, please email Privacy@asksmartypants.com or call 1-203-847-5766. We will acknowledge your request promptly and implement the requested change within a reasonable period. Opting out of the Panel will not, by itself, remove personal data we have previously collected; however, we will do so upon your specific request as described above. Exercising any of these options will not affect incentives you have already earned, nor will it result in any form of adverse treatment by Smarty Pants, LLC.

7) OTHER SITES

Smarty Pants is not responsible for the privacy practices or the content of other Websites. We recommend that you carefully read the privacy policies of each site you visit.

8) YOUR ACCEPTANCE OF OUR PRIVACY POLICIES and CONSENT TO USE YOUR PERSONAL DATA

In order to become a member of our Smarty Pants Circle panel, you will need to intentionally grant us your permission by clicking the “Agree” box in the invitation. In order to participate in any research project conducted by Smarty Pants, you will need to sign a consent form with specific details regarding the collection, processing and storage of your information related to that project. The project-specific consent form will reference this Privacy Statement and your agreement with it. By agreeing to become a Smarty Pants Panel Member or participating in a Smarty Pants research project, you signify your acceptance of the terms and conditions of this Privacy Statement. We will alert you to significant changes to this Privacy Statement by providing you with written, electronic, or other notice from Smarty Pants. You may withdraw your consent at any time by contacting our Privacy Team at Privacy@asksmartypants.com or calling Smarty Pants at: 203-847-5766.