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PRIVACY NOTICE

* TABLE OF CONTENTS
* Privacy Notice
* I. THE BASICS
* 1. Introduction
* 2. Scope of the Privacy Policy
* 3. Definition
* 4. Source of Collection of Information
* II. WHO THIS PRIVACY POLICY APPLIES TO
* Users
* Survey Respondents
* Subscribers ad Visitors
* III. GENERAL INFORMATION
* 1. Use of your information
* 2. Who do we share your Personal Information with?
* 3. Legal Basis for Processing Personal Information
* 4. International Data Transfer
* 5. Retention of Personal Information
* 6. Data Portability
* 7. Our EU Representative
* 8. Our UK Representative
* 9. How we respond to Do Not Track Signals
* 10.0 Third-Party Websites
* 11.0 Third-party links
* 12.0 Google API Disclosure
* 13.0 Privacy Shield Compliance
* 14.0 COPPA (Children Online Privacy Protection Act)
* 15.0 Our Commitment to Data Privacy
* 16.0 Our Approach
* 17.0 Personal Privacy
* 18.0 Transparency
* 19.0 Security
* 20.0 Amendments to Privacy Policy
* 21.0 Unsubscribe From Our Communications
* 22.0. Unsubscribe from Our Customers’ Communication

LEGAL & SECURITY

PRIVACY

PRIVACY NOTICE

Download

Effective Date : 20th September 2023

Click here for the previous version

I. THE BASICS

We at SurveySparrow Inc., and its affiliates/subsidiaries (collectively
“SurveySparrow”, “we”, “us” and “ours”) are committed to protect your privacy
and ensure your Personal Information transfer is transparent and fairer.

1. INTRODUCTION

This Privacy Policy forms an integral part of our

TERMS OF SERVICES.

We recommend that you read this Privacy Policy in full to understand how we
handle your Personal Information and ensure that you are informed of our
privacy practices. We may, at our sole discretion update, alter or change this
Privacy Policy to meet and reflect the changing legal, regulatory and
operational requirements. While we notify you of any material change in this
version of policy via email, we encourage you to review this page periodically
to know the latest update on our privacy practices. If you do not wish to accept
any of the changes updated in this policy please discontinue use of the Services
and/or our website. Please note that your continued use of the Service(s)
following any modification or change to this Privacy Policy constitutes your
acceptance of the amendments to this Privacy Policy.

2. SCOPE OF THE PRIVACY POLICY

This Privacy Policy specifies the types of Personal Information SurveySparrow
Inc., obtains through the SurveySparrow.com website, our product, and services
offered by us, how we may use that Personal Information, with whom we may share
it and how you may exercise your rights relating to our processing of that data.
The Privacy Policy additionally describes the measures we take to secure your
Personal Information and how you can contact us to learn more about our privacy
practices. It covers instances when you contact us, browse our website, use our
Services and products and interact with us otherwise. This Privacy Policy
applies to all the products, services, websites and apps offered by
SurveySparrow Inc., and its affiliates/partners, except where otherwise
specified.

By accessing or browsing our website and using our Services or responding to
surveys, polls, questionnaires etc. sent by our customers, You confirm that You
have read, understood and agree to this Privacy Policy in its entirety. If you
do not agree with the practices described in this Privacy Policy, You should not
use our website or Services.

References to “data” in this Privacy Policy relates to whatever data you collect
using our services, including the responses you receive from your surveys and
the data you enter into our application in the form of email IDs and CSV files
containing information of people to whom you send the surveys. We only process
your data and at any and all times, the data belongs to you and you alone.

For the sake of clarity, this Privacy Policy is applicable to three categories
namely (1) Users; (2) Respondents; (3) Subscribers/Visitors.

3. DEFINITION

Capitalized terms used in this Privacy Policy but not defined herein shall have
the same meaning as defined in the Terms of Service. For the purposes of this
Privacy Policy, following definitions and rules of interpretation shall apply:

“Personal Information” means any information that can be used to identify,
locate, or contact an individual directly or indirectly which is obtained from
or provided by You through the use of website and/or Services.

“User” has the meaning given to it in the Terms of Service located at our
website.

“Respondent” means and includes an individual(s) who receives or responds to
surveys sent by the Users or otherwise interacts with the Users through our
Services.

“Subscriber” means and includes anyone who subscribes to our email
notifications, newsletters, marketing campaigns etc.

“Visitor” means and includes anyone who visits and/or uses or otherwise
interacts with the SurveySparrow website.

“Service” has the meaning given to it in the Terms of Service located at our
website.

“You” and “Your” means, depending on the context, either a User, Respondent,
Subscriber/Visitor or all.

4. SOURCE OF COLLECTION OF INFORMATION

We may collect, process and use information about You when You

1. Register for our Services
2. Interact with our Services
3. Install and/or access our Services through our application(s), including our
mobile application and browser extension
4. Connect to our Services through third parties, including social media
accounts, email accounts and business partners.
5. Contact us for any support
6. Respond to Survey or poll sent by our Users

We collect certain information about You when You submit or provide it to us
directly. When You interact with our Services online, website or through our
mobile applications, we also automatically collect information about You and
Your use of the Services through the use of log processes, cookies and other
similar tracking technologies. Certain other information is collected about you
from third parties, such as when you connect through a third party service or
business partner site.

II. WHO THIS PRIVACY POLICY APPLIES TO

This Privacy Policy applies to three categories, namely Users, Survey
Respondents, Subscribers and Visitors.

1. USERS

For the purpose of this Section “You” and “Your” applies to Users.

1.1 WHAT DO WE COLLECT FROM YOU?

* REGISTRATION INFORMATION

When You register an account on surveysparrow.com, we collect Your Personal
Information including email address, other contact details, IP, location,
device, OS information and certain other information reasonably necessary to
help You create an account pursuant to our provision of Services.

* BILLING INFORMATION

When You make a payment on www.surveysparrow.com in Your preferred payment
method, You’re required to provide billing details, such as name, billing
address, and financial information (like credit card details).

Credit card processing is handled by an intermediary service provider, Stripe on
our behalf who collects Your credit card information to process Your payment to
us. We do not store any such information pertaining to Your credit card. This
third party intermediary shall not use or retain billing information for any
purpose other than that is permitted for processing the payment and related
legitimate interests. By providing such information You represent and warrant
that You are the owner of such Personal Information or otherwise have requisite
consent to provide it to us.

* USAGE INFORMATION AND

ACCOUNT SETTINGS

Whenever You use our websites and Services we may collect usage information
about You like the webpages You visited, language preferences etc. You can set
preferences on the account settings page regarding your default language,
timezone and branding preferences.

* ADDRESS BOOK INFORMATION

You can import email addresses into the audience and make use of it to invite
people to take part of Your surveys. We don’t use the email addresses You have
stored for our own purposes.

* OTHER INFORMATION

We collect information from You through testimonials, case studies, forms or
information You intentionally share with us in other contexts.

Note: We don’t share or abuse your respondents’ email addresses. SurveySparrow
will not email your survey respondents or subscribers in your list except at
your direction. We don’t sell or share the email addresses in your list to any
third parties.

* USER DETAILS

User details such as IP, location, device information and browser information
and its activities will be tracked when a user is interacting with our
application. We also track referral information. Meaning, we also track how the
user landed into SurveySparrow. When a user interacts with our application,
details such as IP, location, device information, browser information and user
activities is tracked.

* EVENT LOGS

A log of all requests generated by the User is maintained to debug in case of
any emergencies. This includes User information such as IP, location, OS
information, browser, device type and the time which the User interacted with
the platform. These log files are encrypted and rotated frequently.

* INFORMATION WE COLLECT FROM THIRD-PARTIES

SurveySparrow Inc. may collect your Personal Information from third parties to
whom You have given Your personal data sharing permissions.

* SURVEY DATA

Your survey data (questions, responses and audience list) is stored with us.
Your survey data is Yours. SurveySparrow Inc., grants you the admin role to
collect and export the responses as you wish. We do not sell or use survey
responses collected by You for our business requirements. This admin role also
grants You the right to edit previously submitted data.

We safeguard survey respondents’ email addresses and the email addresses
collected by You. We don’t use or sell the email addresses against our policy.

The security of Your Personal Information and data is important to us. We store
them securely. We follow generally accepted standards to protect the Personal
Information submitted to us, both during transmission and once it is received.
If You have any questions about the security of Your Personal Information, you
can contact us at privacy@surveysparrow.com

Survey data is stored on servers located either in the United States or EU as
specified by You. We will process Your survey data on Your behalf and under Your
instructions.

1.2 WHEN DO WE COLLECT YOUR PERSONAL INFORMATION ?

We may collect Your Personal Information including but not limited to name,
contact number, email id, credit card information and other related Personal
Information (the details of which are mentioned above) necessary to provide the
Services, when You register for SurveySparrow account or otherwise use our
Services, browse our website or consult with our customer service team and for
our legitimate interests as permitted under the relevant data protection laws.

1.3 YOUR DATA PROTECTION RIGHTS

If you wish to exercise your rights under any applicable data protection law,
including the EU General Data Protection Regulation (GDPR) or the California
Consumer Privacy Act (CCPA) please contact us by email at
privacy@surveysparrow.com

Subject to your applicable data protection laws, you may be entitled to any of
the following rights:

1. Right to be informed of what Personal Information is being processed and the
rationale for such processing.
2. Right to access, update, edit and delete Your information
3. Right to restrict and object to processing of Your information
4. Depending on Your subscription plan You have the right to export Your survey
data from SurveySparrow account in a variety of available formats.
5. Right to complain to a data protection authority about our collection and
use of Your personal information.
6. Right to complain to a data protection authority about our collection and
use of Your Personal Information. However, before referring to your local
supervisory authority, please attempt to resolve the issues directly with
us amicably.

Contact details for data protection authorities in the EEA and UK are available
here and Switzerland are available here.

Note: You will be solely responsible to respond to requests raised by the
respondents in exercise of their data protection rights.

2. SURVEY RESPONDENTS

For the purpose of this Section “You” and “Your” applies to Survey Respondents.

Surveys are administered by our Users. They use our Services to collect Your
information which may or may not include your Personal Information , which we do
not access or use for any purposes other than that is required to provide the
Services to our Users. We host the surveys on our website or app and We act as
an intermediary platform for our Users to collect the responses that you submit
to the survey creators. We only process such data provided by You to our Users
and are limited for the performance of contractual obligations and Services to
our Users. We will not be responsible for security and privacy practices of our
Users which may differ from that is set forth in this Privacy Policy. The
anonymity of Your responses depends on how the survey creator has configured the
survey.

We don’t sell, misuse or share your responses to third party advertisers or
marketers. However, the policy might be different with the survey creator. So
You’re advised to check with them in this regard.

We will not contact You unless directed by our User in which case we will
collect and use Your contact information like name, email address etc. as
provided by our User

If You have any questions about a survey You are taking, please contact the
sender of the survey directly, as SurveySparrow Inc. is not responsible for the
content of that survey or Your responses to it.

2.1 WHAT DO WE RECEIVE FROM YOU?

* CONTACT INFORMATION

You might provide certain Personal Information like name, email id etc. with
our Users when you opt to respond to survey requests. However We will not use
your Personal Information to contact you unless our Users direct us to do so.
If you choose to contact us directly we may use your Personal Information to
communicate with you in response to your queries.

* Internet and other Network Activity, such as Your browsing and search history
and Your interactions with our sites and Services including –

* NAVIGATIONAL INFORMATION

like IP address, geographical location, browser type, device information,
length of visit and pages viewed, URL’s of the pages You visit, including
those tracked by our browser extension; date and time stamps associated with
such browsing, searches, and clicks

* REFERRAL INFORMATION

like the site/link or any place which led You to visit our website – for
example, if You were on social media before clicking on a link to our
website, we record information about the source that referred You to us.

* USAGE INFORMATION.

Whenever You use our websites we may collect usage information about You like
the webpages you visited, language preferences etc.

2.2 WHEN DO WE COLLECT YOUR PERSONAL INFORMATION ?

We will not collect Personal Information from You directly unless our Users
instruct us otherwise or You interact with us. However we may automatically
receive certain information when You opt to interact with us, browse our website
and use our Services.

2.3 YOUR DATA PROTECTION RIGHTS

We only act as a Processor who processes Your data on behalf of our Users. When
You respond to a survey sent by our User through our Services, we recommend You
to contact the relevant User for exercising any of the below mentioned rights.
As we do not have control over your responses, we will not be responsible to
respond to Your requests in relation to Your Personal Information.

If You wish to exercise Your rights under any applicable law, including the EU
General Data Protection Regulation (GDPR) or the California Consumer Privacy Act
(CCPA) please contact us by email at privacy@surveysparrow.com . If You contact
us directly, we may either forward Your request to the relevant User or provide
You with the identity of the respective User to enable You to contact them
directly.

Subject to certain exceptions and limitations under your local law you may be
entitled to exercise the following rights as against the relevant User :

1. Right to be informed of what Personal Information is being processed and the
rationale for such processing.
2. Right to access the Personal Information that is being processed. This also
includes the right to request copies of Personal Information that is being
processed.
3. Right to rectification of Personal Information that is being processed.
This provides the respondent an opportunity to update or modify the Personal
Information that is submitted to the Data Controller.
4. Right to withdraw the previously given consent to process Personal
Information .
5. Right to restrict and object to processing of your Personal Information.
6. Right to erasure otherwise known as right to be forgotten.
7. Right to complain to a data protection authority about our collection and
use of your Personal Information. However, before referring to your local
supervisory authority, please attempt to resolve the issues with us
amicably.

Contact details for data protection authorities in the EEA and UK are available
here and Switzerland are available here.

3. SUBSCRIBERS AND VISITORS

For the purpose of this section “You” or “Your” refer to Subscribers and
Visitors

We may ask You to provide certain information when You register, sign up for our
newsletter or use any features available on the website. We may collect and use
Your navigational information like information about Your device and Your visits
to the Websites such as Your IP address, geographical location, browser type,
referral source, length of visit and pages viewed when You make a visit to our
website. We will not use Your Personal Information for any purpose other than
to communicate with You either in response to Your queries or when You provide
us with Your email id, to send updates about our products, features and services
unless You unsubscribe our Services. We will use such information to send email
campaigns or any other mails related to our products, features and services.

3.1 WHAT DO WE COLLECT FROM YOU?

* CONTACT INFORMATION –

We may collect and use Your Personal Information like name, email address
etc. that You provide to us voluntarily when You visit our website or
subscribe to use any of our products, features and services, when You express
an interest in obtaining information about us or otherwise contact us.

* ANALYTICS –

SurveySparrow Inc. may use Google Analytics to collect information regarding
the behavior and demographics of visitors using our services. To prevent
Google Analytics from processing Your data, please visit
https://tools.google.com/dlpage/gaoptout

* NAVIGATIONAL INFORMATION

like IP address, geographical location, browser type, device information,
length of visit and pages viewed, URL’s of the pages You visit, including
those tracked by our browser extension;

* REFERRAL INFORMATION

* INFORMATION FROM THIRD PARTY SOURCES

like social media platforms and data providers. This includes Your IP
address or any information for which You have given permission to those third
parties to share that information with us or where that information is
publicly available either online or through Your device/browser data.

If You no longer wish to be contacted by Us please unsubscribe from our
Services.

3.2 YOUR DATA PROTECTION RIGHTS

Subject to certain exceptions and limitations under your local law You may be
entitled to exercise the following rights:

1. Right to be informed of what Personal Information is being processed and the
rationale for such processing.
2. Right to access; correct; update; port; delete; restrict or object to our
processing of your Personal Information.
3. Right to complain to a data protection authority about our collection and
use of Your Personal Information. However, before referring to Your local
supervisory authority, please attempt to resolve the issues with us in an
amicable manner.

Contact details for data protection authorities in the EEA and UK are available
here and Switzerland are available here.

III. GENERAL INFORMATION

For the purpose of this Section “You” or “Your” refer to Users, Respondents,
Subscribers and Visitors as applicable unless otherwise specifically mentioned.

1. USE OF YOUR INFORMATION

We may use the information we collect from You when You register, make a
purchase, sign up for our newsletter, respond to a survey or marketing
communication, surf the website, or use any site features. To the extent
permitted by applicable law, We use your Personal Information that either we
collected from or received through our Services in order to perform our
contractual obligations, Services and other legitimate interests that are
further detailed below:

(i) Process Your registration with our Services in accordance with our
legitimate interests to operate and administer our Service. This includes
sending You emails, invoices, receipts, notices of delinquency, and alerting You
if we need a different credit card number. We use third parties for secure
credit card transaction processing, and those third parties collect billing
information to process Your orders and credit card payments.

(ii) To communicate with You about Your account and provide customer support to
perform our contract with You for the use of the Service or where we have not
entered into a contract with You, in reliance on our legitimate interests in
administering and supporting our Service.

(iii)To enforce compliance with our Standard Terms of Service and applicable
law, and to protect the rights and safety of our Users in reliance on our
legitimate interest to protect against misuse or abuse of our Service and to
pursue remedies available. If You use our Services in any way to carry out the
prohibited, unlawful and fraudulent activities and the contents in it are
reported as abuse by anyone including survey respondents we reserve the right to
review Your Content, suspend the Service(s) and block Your account as deemed
necessary.

(iv) To personalize Your experience and to allow us to deliver the type of
content and product offerings You are most interested in;

(ii) To improve our website or services in order to better serve You;

(iii) To allow us to better service You in response to Your customer service
requests;

(iv) To administer a contest, promotion, survey or other site feature;

(v) To quickly process Your transactions;

(vi) To ask for ratings and reviews of services or products;

(vii) To follow up with them after correspondence (live chat, email or phone
inquiries;

(v) To investigate, prevent unauthorized access to the Websites and the
Services, and other prohibited activities for ensuring compliance with our Terms
of Service, applicable laws;

(vi) To carry out other legitimate business purposes, as well as other lawful
purposes;

(vii) for other purposes for which we obtain Your consent

2. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

SurveySparrow Inc. will not share Your Personal Information without Your
consent unless otherwise required by law. SurveySparrow Inc., as a Data
Processor may process and disclose Personal Information to third party
sub-processors for purposes consistent with the clauses mentioned in the DPA
document. We may also share Your Personal Information with third party service
providers for the purpose of delivering improved and better Services to you.

A detailed list of third parties where such information may be disclosed(if
applicable) is provided in Annex III of our DPA document.

We engage third party service providers and business affiliates to provide
complimentary services to us and in connection with this, these third party
service providers and business affiliates may have access to Your information.
For example, we may partner with other third party service providers and
business affiliates to onboard You, provide You customer support services,
authentication services, process payments, administer our promotions etc. These
Service Providers and/or business affiliates, may have access to Your
information in facilitating any onboarding and/or enhancing our Services to You
and may only use Your information for such limited purposes. We do not permit
our third-party service providers and business affiliates to use such
information that we share with them for their marketing purposes or for any
other purpose than in connection with the services they provide to us.

DISCLOSURE FOR LEGAL PURPOSES:

We may also share the information we collect, including Personal Information, to
the extent permitted by applicable law, (i) in response to subpoenas or other
legal processes or if, in our good faith opinion such disclosure is required or
permitted by law without a specific disclosure; (ii) at the request of
governmental authorities conducting an investigation; (iii) to enforce our terms
and conditions or other policies applicable to our Services etc.

3. LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

The legal basis for collecting and processing Personal Information will depend
on the type of Personal Information that we collect and the specific context in
which we collect it. We will collect, use and/or process Your Personal
Information only where such processing is in our legitimate interests, as
permitted by law, and shall not be overridden by Your data protection
interests, rights and freedoms. Our legitimate interests are described in the
General Information Section under the heading “Use of Your Information”.

If you have questions or need further information concerning the legal basis on
which we collect and use your Personal Information, please contact us at
privacy@surveysparrow.com

4. INTERNATIONAL DATA TRANSFER

Currently we have our Data Centers located in the United States and European
Union (EU). SurveySparrow Inc., may transfer Personal Information to the United
States or EU for the performance of Our contractual obligations with You.
SurveySparrow Inc., will follow the requirements of GDPR regardless of where
such Personal Information is stored or processed. We will take all steps
reasonably necessary to ensure that Your Information is treated securely and in
accordance with this Policy. We will not transfer Your Personal Information
without Your consent and ensure to have appropriate safeguards in place.

For more information, please refer to our DPA document, section International
Transfer of Data.

5. RETENTION OF PERSONAL INFORMATION

SurveySparrow Inc., stores User data with reference to Your Service account.
This may include Personal Information, survey data and other details that You
enter into the app from time to time. We will retain Your Personal Information
as long as you have an account with us in order to maintain and expand our
relationship with You and in order to have proof and evidence concerning our
relationship with you. Please note that except as required by applicable law or
our specific agreements with you, we shall not have any obligation to retain
your data for any particular period. Upon termination or expiry of your
account, not exceeding 30 (thirty) days from the date of such expiration or
termination, we will delete all Personal Information including any copies
thereof. If it is a HIPAA enabled account we will immediately delete or destroy
the PHI received, provided or processed pursuant to signing a BAA with You. In
case, we are unable to delete Your Personal Information due to technical or
other reasons, SurveySparrow Inc., will apply measures to ensure that Your
Personal Information is blocked from any further processing until deletion is
possible. This excludes the data that we are required to retain for legal and
regulatory requirements.

6. DATA PORTABILITY

Being the data owner, it is completely your call to decide on where & with whom
your data must reside. You can use our standard data export functionality or API
to export the data. In any event of this not working for you, We will help you
to export your data

7. OUR EU REPRESENTATIVE:

Under Article 27 of the GDPR , we have appointed an EU Representative to act as
our data protection agent. Our nominated EU Representative is :

Instant EU GDPR Representative Ltd

Adam Brogden

contact@gdprlocal.com

Tel + 353 15 549 700 /

EU Dublin Address

INSTANT EU GDPR REPRESENTATIVE LTD 69 Esker Woods Drive, Lucan Co. Dublin
Ireland

8. OUR UK REPRESENTATIVE:

Under Article 27 of the GDPR , we have appointed a UK Representative to act as
our data protection agent. Our nominated UK Representative is :

Instant UK GDPR Representative Ltd

Adam Brogden

contact@gdprlocal.com

Tel + 441 772 217 800

GDPR Local Ltd 1st Floor Front Suite 27-29 North Street, Brighton England BN1
1EB

9. HOW WE RESPOND TO DO NOT TRACK SIGNALS:

If you wish to prevent SurveySparrow Inc. from processing your data, you can
enable the Do Not Track(DNT) signal in your browser settings. This will disable
tracking whenever you visit our website.

10. THIRD-PARTY WEBSITES

We do not sell, trade, or otherwise, transfer to outside parties your Personally
Identifiable Information. This does not include website or service hosting
partners and other parties who assist us in operating our website or services,
conducting our business, or serving our users, so long as those parties agree to
keep this information confidential. We may also release information when its
release is appropriate to comply with the law, enforce our site policies, or
protect ours or others’ rights, property or safety.

11. THIRD-PARTY LINKS

Occasionally, at our discretion, we may include or offer third-party products or
services on our website. These third-party sites have separate and independent
privacy policies. We, therefore, have no responsibility or liability for the
content and activities of these linked sites. Nonetheless, we seek to protect
the integrity of our site and welcome any feedback about these sites.

12. GOOGLE API DISCLOSURE

SurveySparrow has introduced a feature that enables its users to link their
Gmail accounts via OAuth with the SurveySparrow platform without any manual
authentication using legacy methods. By integrating your Gmail with your
SurveySparrow Account, SurveySparrow can synchronize with your personal data on
Google, access information you’ve made available, and view your email address.
The connection will allow you to respond to your emails directly from our
product and to delete them once they are fetched into our product.
SurveySparrow’s handling of data obtained from Google APIs is in strict
compliance with the Google API Services User Data Policy, including its Limited
Use clause. Additionally, Workspace APIs will not be used to develop, improve,
or train generalized AI and/or ML models.

13. PRIVACY SHIELD COMPLIANCE

The EU-U.S. and Swiss-U.S. Privacy Shield Frameworks were designed by the U.S.
Department of Commerce, and the European Commission and Swiss Administration,
respectively, to provide companies on both sides of the Atlantic with a
mechanism to comply with data protection requirements when transferring personal
data from the European Union and Switzerland to the United States in support of
transatlantic commerce.

The historic judgment in Case C-311/18 Data Protection Commissioner v Facebook
Ireland and Maximillan Schrems (Schrems II) on 16th July 2020 invalidated the
EU-US Privacy Shield framework, a framework that allows unrestricted transfers
of personal data from the EU to certified US-based organisations that have
agreed to higher standards of data protection. Additionally, followed by the
landmark Schrems II case on September 8, 2020, the Swiss Data Protection
Authority announced that it no longer considers the Swiss-U.S. Privacy Shield
adequate for the purposes of transfers of personal data from Switzerland to the
U.S. However we undertake to contractually commit to transfer and process all of
our Users’ data in compliance with the Standard Contractual Clauses, which
remain a valid data export mechanism and which automatically apply in accordance
with our DPA.

14. COPPA (CHILDREN ONLINE PRIVACY PROTECTION ACT)

When it comes to collection of personal information from children under the age
of 13 years, the Children’s Online Privacy Protection Act (COPPA) puts parents
in control. The Federal Trade Commission, United States’ consumer protection
agency, enforces the COPPA Rule, which spells out what operators of websites and
online services must do to protect children’s privacy and safety online.

Do we let third-parties, including ad networks or plug-ins, collect PII from
children under 13?

Our Services and website are not intended to target children under 13 years of
age(“Minor”). Neither do we specifically market and allow Minors to register
with us nor knowingly collect Personal Information from Minors. If you have
reasons to believe that a Minor has accessed our website and/or has registered
with us to create an account, please contact privacy@surveysparrow.com. We shall
take reasonable efforts to terminate that account and delete the information.

WE DO NOT SELL YOUR PERSONAL INFORMATION

The CCPA requires businesses to disclose whether they sell Personal Information.
SurveySparrow does not sell your Personal Information. This means that we do not
rent, disclose, release, transfer, make available or otherwise communicate that
personal information to a third party for monetary or other valuable
consideration.

15. OUR COMMITMENT TO DATA PRIVACY

SurveySparrow Inc. gives utmost importance to the data privacy of its customers.
In compliance with the GDPR regulation, effective from May 25, 2018,
SurveySparrow Inc., hereby confirms upon the data privacy, security &
transparency commitment, the company offers to all its customers.

We have an up-to-date Data Processing Agreement in place that elucidates our
approach towards GDPR. We acknowledge that the GDPR will help us adopt the
highest operational standards and will thereby facilitate protecting customer
data in the best way possible.

16. OUR APPROACH

It is pretty straightforward. We strive for Transparency, Privacy, and Security.
We are the facilitators who make data processing and management simple for you.
You control and own your data!

17. PERSONAL PRIVACY

Personal Privacy of customers data is absolute at SurveySparrow Inc. While we
will process customer data, it is the customer on whom the power to edit,
delete, retain or transfer any of such data, fully rests upon. You are entitled
to exercise your data protection rights subject to your applicable data
protection laws, to the extent we act as Controller and collect your Personal
Information.

18. TRANSPARENCY

Customers at any point in time can get in touch with us and conduct audits on
their Personal Information . They can approach the Data Privacy Officer (DPO) by
sending an email to privacy@surveysparrow.com and ask for any information
pertaining to their account. If deemed necessary, customers can also verify
their logs to confirm upon specific events related to their Personal Information
.

19. SECURITY

We promise to adopt utmost security standards so that your Personal Information
does not get compromised at any point in time. We have tightened our IT
infrastructure, data security platform & IT policies so as to offer our
customers, enhanced end-to-end security.

20. AMENDMENTS TO PRIVACY POLICY

SurveySparrow Inc., reserves the right to make changes to this Privacy Policy
from time to time. We will post the revised version on the website along with
the effective date. In case there are any material changes in the way we
collect/handle your information we will notify you about the policy changes via
email, irrespective of whether you have opted-in or opted-out of our email
notifications. However, your continued use of our Services would imply your
consent to the amendment of our Privacy Policy. If you do not accept the terms
of this Policy or any amendments made to it, you may choose to discontinue use
of our website or Services.

21. UNSUBSCRIBE FROM OUR COMMUNICATIONS

If you want to unsubscribe from our marketing communications, you can do so by
clicking on the “Unsubscribe” link provided at the bottom of the emails,
updating your communication preferences, or by sending an email to
support@surveysparrow.com

Please note that Customers cannot unsubscribe from transactional emails which
relate to their account or the Subscription Service.

22. UNSUBSCRIBE FROM OUR CUSTOMERS’ COMMUNICATION

Our Customers are solely responsible for their marketing emails and any
communications. Thus we cannot unsubscribe you from their communications. You
can unsubscribe from our customers’ marketing communications either by using the
“Unsubscribe” link provided at the end of the emails, or by directly contacting
them.

HOW TO CONTACT US?

If you have any questions regarding our privacy policy, feel free to send us an
email at privacy@surveysparrow.com. We will revert to you within a maximum of 15
business days.

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