Link Group – California Consumer Privacy Act

CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

The CCPA requires that organizations are transparent about and tell individuals what personal information they collect and store, how it is used, and how to ensure that personal information is adequately secure. The CCPA gives the consumer rights to access and port and to delete their personal information, to optout of having their personal information sold and to not suffer discrimination for asserting their rights by way of affecting the services and prices that the organization offers.

Our goal in posting our approach to compliance with the CCPA is to be fully transparent so you, the consumer, understand how we handle personal data in our marketing research activities.

WHO WE ARE WHAT TYPES OF CCPA DATA CATEGORIES DO WE COLLECT OR STORE?

In the table below, we explain how we do or do not collect and store data in the eleven (11) different categories specified in the CCPA.

Category	Examples for Link Group Marketing Research Studies	Collected (for use during a marketing research study)	Stored (beyond the duration of the study)
Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers	Yes – we may collect partial information (e.g., first name, IP address for an online survey) as part of our market research study, but we do not store this information. We do NOT collect Social Security numbers, driver’s license numbers, passport numbers or any other similar identifiers.	No
Personal Information listed in customer records (Cal. Civ. Code 1798.80 (e))	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	Yes – we may collect health information (with your consent) as part of the screening process for participation in a market research study, or during the conduct of a marketing research study if it is relevant and necessary to the purpose of that specific study. We do not collect any specific personal financial information, such as bank account or credit card account numbers. We may receive an address or phone number on projects where it is necessary for us to have this information (e.g., an ethnography research study).	No
Legally Protected Characteristics	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Yes – we may collect information about age, gender, ethnicity, or medical condition as part of the screening process for participation in a market research study, or during the conduct of a marketing research study if it is relevant and necessary to the purpose of that specific study.	No
Commercial Purchasing Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes – we may ask you about past purchase behavior or intended future behavior as part of the screening process for participation in a market research study, or during the conduct of a marketing research study if it is relevant and necessary to the purpose of that specific study.	No
Biometric Information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No	No
Internet or Network Activity	Browsing history, search history, information on interaction with a website, application or advertisement	Yes – We may collect information on your interaction with a website, application or advertisement as part of a market research study that you consent to participate in, but we do not store this information. We do not collect browsing history or search history.	No
Geolocation	Physical location or movements	No	No
Sensory Data	Audio, electronic, visual, thermal, olfactory or similar information	Yes – We may collect audio data (e.g., recordings of research sessions) or eye tracking data (e.g., for website usability studies), but we will clearly explain any data that we may collect before the study and obtain your informed consent before you participate in the study.	No
Employment Information	Current or past job history or performance evaluations	Yes – We may ask about your current employment status or job / industry of employment as part of our screening process for marketing research studies, but we do not store this information.	No
Education Information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No	No
Inferences drawn from personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	No	No

 

WHEN DO WE COLLECT YOUR PERSONAL INFORMATION?

In the course of conducting marketing research studies, we may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). Note that as a general rule, we operate on a “minimum data necessary” principle and collect only the information necessary for our marketing research studies. We intentionally avoid collecting any personal information that is not relevant or necessary for the specific study, and we do not maintain a consumer database. We work with marketing research vendor partners (for example, focus group facilities or consumer research panels) who do maintain their own databases, but we do not have direct access to those databases. In addition, we ensure that our vendors with whom we conduct reach in California are also CCPA compliant.

HOW DO WE USE THE PERSONAL INFORMATION WE COLLECT?

We may use or disclose the personal information we collect to fulfill the requirements of the research study you are participating in – for example, if we are conducting a study among people diagnosed with Type 2 diabetes, we will ask during the course of screening for the study what medical conditions you have been diagnosed with. We may also ask about your age, the time since diagnosis, and what medications you currently use to help determine if you meet the criteria for participation in the study. Note that any information you provide to us during the screening or participation in a market research study is provided on a voluntary basis; you have the right to opt out / choose not to participate in a study. For each study we conduct, we provide information to our research participants regarding how the information collected will be used, and we analyze and report on data collected on an anonymized basis – that is, the feedback you provide in research will not be attributed to you by name or by any other specific personally identifiable information.

 

SHARING OF PERSONAL INFORMATION

If you participate in a marketing research study with The Link Group, your research session may be viewed by Link Group team members or client observers. During the course of research, a Link Group team member or client observer may:
– See you
– Hear your voice
– Learn your first name
– Learn your age and gender
– Learn about your health conditions if you are participating a healthcare-oriented research study

All of this information is shared by you on an informed consent basis; we will explain to you the purpose of the research and the type of information that will be shared during the recruiting process, and again at the start of your participation in a research study. You will have the option to decline to participate in the study if you desire.

The Link Group does not rent, sell, or share your personal information with other people or nonaffiliated companies. The Link Group is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, and The Link Group assumes liability in cases of onward transfers to third parties. In the preceding 12 months we have not sold any personal information

 

YOUR CONSUMER RIGHTS UNDER CCPA

 

RIGHT OF ACCESS AND DATA PORTABILITY

You have the right to request that we disclose personal information that we collect from you and use within the last 12 months. If you contact us directly, once we can verify your identity, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business purpose for collecting that personal information. • Your right to data portability

RIGHT TO LIMIT USE AND DISCLOSURE

You have the right to limit the use and disclosure of sensitive personal information collected about you as a consumer. For example, you have the right to limit how your sensitive personal information is disclosed or shared with third parties, as defined by the CCPA.

RIGHT TO CORRECTION OR DELETION

You have the right to request that we correct or delete any of your personal information that we collected from you and retained, subject to certain exceptions. For example, you have the right to request that we correct any inaccuracies in your personal information. Once we receive and confirm your verifiable consumer request, we will correct your information or delete your personal information from our records and will direct our service provider / vendor partners to do the same.

Note that as stated previously, we do not maintain personal information or a research consumer database, so we may need to direct you to the agency partner we worked with on the study you participated in to have you request data deletion directly with them. We will assist you with this request and put you in contact with the appropriate party at our agency partner.

To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by:

Sending an email to privacy@tlg.com

Or Calling our toll-free number – 1-888-954-6537 – and asking for our privacy manager.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of a minor (child). You can make a request twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient evidence that allows us to reasonably verify you are the person that we collected personal information from, or you must be their authorized representative.

• Be precise about your request and provide sufficient detail that allows to properly understand, evaluate and respond to it.

Note that we cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

 

RESPONSE AND TIMING

We aim to respond to a verifiable consumer request within 45 days. If we need more time (up to 90 days), we will inform you in writing of the reason and the time extension required. Please note any disclosures we provide are for the 12-month period preceding the verifiable request. If we are unable to comply with your request, then we will advise you of the reasons. For data portability requests we will provide your information in a readily usable format that means the information can be transferred to you easily.

We do not charge a fee to respond to a verifiable request, unless it is excessive, repetitive or unfounded. If it is our judgement that a fee is warranted then we will advise you of the reason for this and the costs involved, before completing the request.

 

RIGHT TO OPT-OUT

The Link Group does not sell personal information as defined by the CCPA. If you wish to contact our vendor partners, we can help you do this.

We do not charge a fee to respond to a verifiable request, unless it is excessive, repetitive or unfounded. If it is our judgement that a fee is warranted then we will advise you of the reason for this and the costs involved, before completing the request.

If you are a member of a consumer research panel and wish to be removed from the panel, the best approach would be for you to contact the panel company directly. You can email us at optout@tlg.com and you will be removed from any email invitations coming directly from The Link Group.

 

RIGHT TO NON-DISCRIMINATION

You have the right to not receive discriminatory treatment by The Link Group if you choose to exercise your privacy rights conferred by the CCPA. If you have further questions about our approach to the CCPA, please contact us:

Email: privacy@tlg.com

Phone (toll free): 1-888-954-6537 (please ask for the privacy manager)