This Privacy Policy applies to three categories, namely Users, Survey Participants, 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
www.thrivesparrow.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.thrivesparrow.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 Participants’ email addresses. ThriveSparrow will not email your survey Participants 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 ThriveSparrow. 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 Participants’ 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@thrivesparrow.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 ThriveSparrow 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 ThriveSparrow 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 Participants in exercise of their data protection rights.
2. Survey Respondents
For the purpose of this Section “You” and “Your” applies to Survey Participants.
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@thrivesparrow.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 Participants 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 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.
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
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@thrivesparrow.com.
Subject to certain exceptions and limitations under your local law You may be entitled to exercise the following rights:
- Right to be informed of what Personal Information is being processed and the rationale for such processing.
- Right to access; correct; update; port; delete; restrict or object to our processing of your Personal Information.
- 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.
For the purpose of this Section “You” or “Your” refer to Users, Participants, 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 Participantss 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 to provide complimentary services to us and in connection with this, these third party service providers may have access to Your information. For example, we may partner with other third party service providers to provide You customer support services, authentication services,, process payments, administer our promotions etc. These Service Providers may have access to Your information in facilitating and enhancing our Services to You and may only use for such limited purposes. We do not permit our third-party service providers 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 07 (seven) days from the date of such expiration or termination, we will delete all Personal Information including any copies thereof. 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. Cookie Policy
Cookies are small files that a site or its service provider transfers to your browser that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. They are also used to help us understand your preferences based on previous or current site activity which enables us to provide you with improved user experience and services. SurveySparrow Inc., also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.
We use cookies to:
– Help remember and process the user's chosen plan.
– Understand and save user’s preferences for future visits.
– Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You can do this through your browser settings. Since each browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.
If users disable cookies in their browser
If you turn cookies off, some of the features that make your site experience more efficient may not function properly.
10.0 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.
11. 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.
12. 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.
13. Privacy Shield Compliance
Our commitment to data protection extends beyond mere compliance. We undertake to contractually commit to transfer and process all of our Users’ data in compliance with the new Standard Contractual Clauses adopted by the EU Commission on 4 June 2021, replacing the old SCCs that were adopted under the previous Data Protection Directive (Directive 95/46), which remains 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@thrivesparrow.com. We shall take reasonable efforts to terminate that account and delete the information.
15. 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.
16. 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.
17. 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!
18. 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.
19. 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@thrivesparrow.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 .
20. 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.
21. 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.
22. 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@thrivesparrow.comPlease note that Customers cannot unsubscribe from transactional emails which relate to their account or the Subscription Service.
23. 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.
24. How To Contact Us?
If you have any questions regarding our privacy policy, feel free to send us an email at privacy@thrivesparrow.com. We will revert to you within a maximum of 15 business days.
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